Court of Justice 29 June 2006, C-524/04 (Test Claimants in the Thin Cap Group Litigation v Commissioners of Inland Revenue.)

Opinion of the Advocate-General Opinion of the Advocate-General I – Introduction 1. The present case, a preliminary reference from the High Court of Justice of England and Wales, concerns the compatibility with the Treaty free movement provisions of the UK’s so‑called ‘thin capitalisation’ (‘thin cap’) rules, as variously amended, by which the UK restricts the deductibility of interest payments