Court of Justice 6 April 2006, C-446/04 (Test Claimants in the FII Group Litigation v Commissioners of Inland Revenue.)

Opinion of the Advocate-General Opinion of the Advocate-General I – Introduction 1. The present case arises from the same underlying legislation as is at issue in the pending Case C‑374/04 Test Claimants in the ACT Group Litigation , (2) namely, the UK’s regime of Advance Corporation Tax (‘ACT’) in force between 1973 and 1999.