“… the Marks & Spencer case (to which we will need to return) in July 2002: see Case C-62/00Marks & Spencer plc v Customs and Excise Commissioners EU:C:2002:435, [2003] QB 866 (“Marks & Spencer”). The Revenue sought to justify this omission, however, by deploying arguments that the unheralded curtailment of the limitation period for …”
“…legislation, with effect from the date when the proposal to reduce the limitation period was announced (with no prior notice) in Parliament. As the headnote at [2003] QB 866 records:…”
“… within which repayment could be sought of sums collected in breach of EU law is incompatible with the principle of effectiveness: see the Marks & Spencer case [2003] QB 866, para 47.”…”