Case C-374/04: Judgment of the Court (Grand Chamber) of 12 December 2006 (reference for a preliminary ruling from the High Court of Justice of England and Wales, Chancery Division, United Kingdom) — Test Claimants in Class IV of the ACT Group Litigation v Commissioners of Inland Revenue (Freedom of establishment — Free movement of capital — Corporation tax — Payment of dividends — Tax credit — Separate treatment of resident and non-resident shareholders — Bilateral double taxation conventions)