Cable & Wireless & Pacific Holding BV (in liquidation) v FCT – High Court refused the taxpayer leave to appeal the FFC decision that denied it a refund of $452m dividend withholding tax on its share of the $3.9b Optus share buy back – the amount was not paid from an untainted share capital account

The High Court on 14 September 2017 dismissed the taxpayer’s application for special leave to appeal from the Full Federal Court decision in Cable & Wireless & Pacific Holding BV (in liquidation) v FCT [2017] FCAFC 71. The Full Federal Court decision, which now stands, unanimously dismissed the taxpayer’s appeal against a decision that it was not…