Non-discrimination and group income elections

On 23 May 2007, the House of Lords gave judgment in the case of Boake Allen Ltd v. HMRC [2007] UKHL 25 concerning the group litigation order (GLO) claiming that a group comprising a UK resident subsidiary and a parent company resident outside the European Union is entitled to compensation for having had to pay Advance Corporation Tax (ACT) on UK dividends that could have been avoided by a group income election under Sec. 247 of the Income and Corporation Taxes Act 1988 (ICTA). Th…