The claim, by Pirelli, was about the charging of ACT on international
dividends. Graham Aaronson QC, for Pirelli, said that the group should receive
an interest payment on the ACT as it was payable earlier than corporation tax.
The company received tax credits later instead, but Pirelli wanted both.
Justice Rimer, who heard the case, however, said this argument amounted to
nothing more than ‘the assertion that Pirelli must be entitled to the claimed
credit because it must be entitled to it’.
For the full judgment see
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