As reported previously, on 12 December 2006, the European Court of Justice (ECJ) gave its decision in the case of Test Claimants in Class IV of the ACT Group Litigation v. Commissioners of Inland Revenue (C-374/04) regarding the compatibility with the EC fundamental freedoms of the previous UK rules governing the entitlement to tax credits on dividends paid by UK resident companies to non-residents. The rules at issue in this case formed part of the UK's partial imputation and advance corporation tax (ACT) system, which were in force prior to 6 April 1999. Details of the judgment are summarized below....