The tribunal rejected an appeal by G E Financial Investments to amend its corporation tax returns to exclude credit claimed for foreign tax through double tax relief for its accounting periods ending 31 December 2003 to 31 December 2008. This tax bill accumulated to £124,913,161.

The tax bill for G E Financial Investments is a seperate case to the larger ongoing dispute with HMRC over what the tax authority states was possible fraud because G E Financial Investments failure to disclose information on a 2005 investment in Australia.

HMRC opened an enquiry under Finance Act 1998 Schedule 18 paragraph 24 into each of G E Financial Investments company tax returns for the relevant period. On 24 May 2017, HMRC issued closure notices under Schedule 18 paragraph 32 of those enquiries.