“…e relying upon the supposed validity of a void transaction. Mr Paul also referred to the decisions of Henderson J in the FII litigation ([2008] EWHC 2893 (Ch); [2009] STC 254 and [2014] EWHC 4302 (Ch); [2015] STC 1471) that the Revenue should not be entitled to rely on change of position as a defence to a Woolwich claim, because suc…”
“…KHL 34, [2008] 1 AC 561 and the judgment of Henderson J in Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners[2008] EWHC 2893 (Ch), [2009] STC 254, at [405] to [406].…”