Attorney-General, Joined Cases C-397/98 and C-410/98  ECR I-1727,  Ch 620 (the Hoechst case), certain parent companies which are citizens of countries other than the United Kingdom (here, two from the United States) which lie outside of the European Union, filed suits in the English Courts against the Commissioners for Her Majesty's Revenue and Customs (Commissioners) over their liability to pay an Advance Corporation Tax
This decided that it was unlawful for the Inland Revenue to impose advance corporation tax
on dividends paid by UK companies to parent companies based elsewhere in Europe.
The removal of the advance corporation tax
credit for pension funds was cited as a major reason for the shift.
The British government threatened to deny refunds of advance corporation tax
(ACT) to U.
Company Distributions, Tax Credits, Franked Investment Income And Advance Corporation Tax