HMRC Wins Redo In Foreign Unit Dividend Fight At Top Court

Law360, London (November 20, 2020, 5:46 PM GMT) -- HM Revenue & Customs scored a win Friday in long-running litigation brought by multinationals claiming they were illegally overtaxed on dividends, after the U.K.'s highest court ruled that the lower courts used the wrong test to assess which claims were filed too late.

The U.K. Supreme Court allowed HMRC's appeal, concluding that the Court of Appeal applied the wrong principles to establish the deadline for filing claims. But the justices held back on settling when exactly the mistaken payments could have been discovered and sent the case back down for another look.

Justice Robert Reed said the court's conclusions are a...

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