“…ion period, but it had an analogous effect and similar principles must apply. As Lewison LJ explained in Leeds City Council v Revenue and Customs Commissioners [2015] EWCA Civ 1293, [2016] STC 2256 (“Leeds CC”) at [41], citing Fantask A/S v Industriministeriet (Erhvervsministeriet) (Case C-188/95) [1998] All ER (EC) 1, [1997] ECR I-6783 a…”
“…resolved in HMRC’s favour at all levels below the Supreme Court by the decision of the Court of Appeal in Leeds City Council v Revenue and Customs Commissioners[2015] EWCA Civ 1293, [2016] STC 2256 (“Leeds City Council”). Jazztel’s skeleton argument in support of its appeal is therefore confined to preserving its position on the issue pen…”
“… effectiveness and equal treatment. But its appeal was withdrawn following the decision of this Court in Leeds City Council v Revenue and Customs Commissioners [2015] EWCA Civ 1293, [2016] STC 2256 and Rank now accepts that claim (iv) was out of time.…”