The appellant, GE Financial Investments (GEFI Ltd), tried to amend its corporation tax returns to exclude credit claimed for foreign tax through double tax relief amounting to £124,913,161.

HMRC opened an enquiry into the company’s tax returns for the accounting periods ending 31 December 2003 to 31 December 2008.

On 24 May 2017, the tax authority issued closure notices under Schedule 18 of Finance Act 1998, which amended the company’s tax returns to deny all claims for foreign tax credits for that period.

In total, the tax bill was £124.9m. The tax assessed in the UK was then paid by GEFI in November 2021 to stop the accrual of further interest, which was £63,717,137.

The company paid just under £189m in total for the disputed claims for double taxation relief.