‘Tax Restitution Claims Curtailed by the Supreme Court’s Limitation Discoverability Doctrine’

“Jazztel Plc v HMRC [2022] EWCA Civ 232 is the first judgment to apply the discoverability doctrine from Test Claimants in the Franked Investment Income Group Litigation v HMRC [2020] UKSC 47 (FII) to a pleading to postpone limitation on the basis of mistake of law. Discoverability is a principle for construing limitation periods. Under the Limitation Act 1980 (E&W), typically a limitation period commences from the date at which a cause of action accrued …” (more)

[Samuel Beswick, Oxford Business Law Blog, 1 April]

First posted 2022-04-01 14:00:00

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