On 16 May a decision was reached by the Upper Tribunal (“UT”) in the Coal Staff Superannuation Scheme Trustees Limited v HMRC case, determining that the application of the UK Relevant Withholding Tax (“RWT”) on Manufactured Overseas Dividends (“MODs”) was contrary to EU law principles in the case of a pension fund recipient.
This case had previously been heard by the First Tier Tribunal (“FTT”) who had found against the taxpayer. The taxpayer had subsequently appealed to the UT.
