1973 | Advance corporation tax (ACT) is introduced (section 84, Finance Act 1972). |
1995 | Hoechst and Metallgesellschaft issue claims challenging the validity of section 247 of the Income and Corporation Taxes Act 1988 (section 247). |
1999 | ACT is abolished (section 31 and paragraph 8, Schedule 3, Finance Act 1998). |
18 October 2000 | Deutsche Morgan Grenfell Group plc (DMG) issues claim. |
8 March 2001 | The European Court of Justice holds that section 247 is contrary to the EC Treaty to the extent that it limits availability of a group income election to companies with UK resident parent companies (Metallgesellschaft and others v Commissioners of Inland Revenue and another (Joined Cases C-397/98); Hoechst AG and another v Commissioners of Inland Revenue and another (C-410/98); www.practicallaw.com/5-101-4268). |
26 November 2001 | The ACT Group Litigation Order is made. |
12 March 2002 | DMG is appointed as a test case on so-called EU limitation issues. |
18 July 2003 | The High Court finds in favour of DMG (www.practicallaw.com/9-102-4166). |
8 September 2003 | The introduction of section 320 of the Finance Act 2004 (section 320) is announced, in response to the High Court’s decision. |
22 July 2004 | Section 320 comes into force. |
4 February 2005 | The Court of Appeal overturns the High Court’s decision and holds that taxpayers who make a payment to HM Revenue & Customs (HMRC) under a mistake of law are not entitled to a restitutionary remedy against HMRC (www.practicallaw.com/3-200-5532). |
25 October 2006 | The House of Lords overturns the Court of Appeal’s decision. |