Withholding tax for manufactured overseas dividends in stock lending transactions
– issue whether tax contravenes Article 63 TFEU and whether it is justified –
proposed reference to the CJEU before substantive appeal – Art 267, Treaty on the
Functioning of the European Union – forthcoming exit of UK from the EU -
whether questions of EU law should be referred to the CJEU – principles to be
applied – decision not to refer.