[2015] EWCA Civ 713

Court of Appeal (Civil Division)

[The appeal against this decision is reported at [2017] BTC 34.]

Lord Justice Patten, Lord Justice Briggs, and Sir Colin Rimer

Judgment delivered 9 July 2015

Tax credit – Foreign income dividends – Claim by Trustees of exempt approved pension scheme – FIDS received from UK-resident companies – Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 231.

Tax credit – Cross-border dividends – Claims for tax credits based on ECJ decision in Re Manninen (Case C-319/02) [2007] BTC 163 – Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 231.

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