Court of Justice 23 February 2006, C-374/04 (Test Claimants in Class IV of the ACT Group Litigation v Commissioners of Inland Revenue.)

Opinion of the Advocate-General Opinion of the Advocate-General I – Introduction 1. The principal question raised by the present case, a preliminary reference from the High Court of Justice of England and Wales, Chancery Division, is the compatibility with Articles 43 or 56 EC of the United Kingdom’s denial of tax credits to non‑UK‑resident companies receiving dividends from UK‑resident