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
* A subsequent government abolished the right of pension funds to reclaim advance corporation tax
credits--estimated to be worth 5 billion [pounds sterling] a year.
"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.