Tax and the City briefing for June 2012

In the next instalment of FII Group Litigation, the Supreme Court is divided over whether to uphold statutory rules designed to prevent the government having to repay billions of pounds of tax levied in contravention of EU law. French rules requiring tax to be withheld from dividends paid to non-French UCITS are held to be non-compliant with EU law in Santander. HMRC outlines the shape of the new rules for unauthorised unit trusts. A consultation is launched on the new tax charges relating to residential properties held by corporates. The status quo is to be maintained for holders of depositary receipts.