“…ey do not render practically impossible or excessively difficult the exercise of rights conferred by EU law (the principle of effectiveness): see, for example, Case C-362/12Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners EU:C:2013:538 and 834, [2014] AC 1161 (“FII (CJEU) 3”) at paragraphs 30 to 32 of …”
“…present appeal. The Court’s decision was not based on any standstill provision, but rather on the principle of effectiveness. As can be seen from, for example, Case C-362/12 Test Claimants in the Franked Investment Income Group Litigation v Commissioners of Inland Revenue [2014] 2 CMLR 33 (at paragraph 32 of the judgment), the prin…”