Just a quick note to a reference in CCH tax news to a decision in the European Court of Justice in Test Claimants in the FII Group Litigation v IR Commrs (Case C-362/12).
The decision was that legislation introduced in the UK in 2004 which retroactively abolished the extended limitation period available for Kleinwort Benson claims was contrary to EU law.
I might do a longer post on this when (and if) I can work out what it means.
The link to CCH is here but I'm not sure if you'll be able to follow unless you subscribe.
CCH
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