“… on a periodic basis (see Caffoor v Income Tax Commissioner [1961] AC 584, discussed in detail in a VAT context by Henderson J in the High Court in Littlewoods [2014] EWHC 868 (Ch), [2014] STC 1761), in this case the common law claim relates to precisely the same tax as was the subject of the statutory appeal. For that reason it seems to …”
“…There is a perceptive and useful analysis of the Caffoor decision by Henderson J (as he then was) in Littlewoods Retail Ltd v Revenue and Customs Commissioners [2014] EWHC 868 (Ch) at [169]-[175] where the judge expresses the view that the Caffoor principle remains good law in relation to annually assessed taxes such as income and capital…”