Alison Foster QC has successfully defended HMRC’s 45% withholding tax in a decision released on the 12th July 2017. In BAT Industries and others v HMRC  UKFTT 558 (12 July 2017), the FTT found that CTA 2010 Part 8C was lawful. Several companies of the British American Tobacco group had appealed against the deduction of HMRC of withholding tax on payments of restitution interest awarded to BAT as test claimants in the “Franked Investment Income Group Litigation Order.”
Alison led a team comprising a specialist tax silk and 4 juniors resisting this EU law and ECHR challenge to a corporation tax measure.
To read the full judgment see here.