HMRC told to pay up to £6m in FII Group litigation costs

The High Court has ordered HMRC to pay the lion’s share of an estimated £9m in costs claimed as a result of the long running and highly complex Franked Investment Income (FII) group litigation, which relates to the different UK corporation tax treatment of UK and foreign dividends in the hands of UK companies, reports Pat Sweet

The substantive issues have already had three appearances before the High Court, two before the Court of Appeal, one before the Supreme Court and in respect of which three rulings have been sought from the European Court of Justice (ECJ).

The latest judgment was solely concerned with issues regarding costs in the case, with the judge describing the background and history of the litigation as being ‘of quite exceptional complexity.’[The test claimants in the FII Group litigation and the Commissioners of Inland Revenue, the Commissioners for her Majesty’s Revenue and Customs; [2015] EWHC 2883 (Ch); Case No: HC03C02223 & Others]

Thi

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