Both sides in the in the Prudential Portfolio Dividends case have been given permission to appeal the High Court decision. If you follow the link below there's a bit more detail. If I'm reading this correctly; although the question of exemption vs underlying relief at nominal rate vs underlying relief at actual rate only is going to the Court of Appeal, the High Court is retaining control of the "computational issues", i.e. if you use a nominal rate then how, exactly does that work in practice. I think this is a good thing as it cuts down HMRC's scope to constantly litigate on points of detail.
Also the Joseph Hage Aaronson site is a very well set out summary of high profile ongoing tax cases and it includes an update on the The Trustees of the BT Pension Scheme v HMRC [2014] EWCA Civ 23, which I have posted on. The site is
And finally a bit of in blog advertising: my post of 4th February on offshore bond funds is, in my opinion, worth five minutes of your time.
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