“…t of Marcus Smith J (“the Judge”), which he handed down on 3 April 2017 after the trial of the action over four days in late January 2017 (“the Judgment”): see [2017] EWHC 677 (Ch), [2017] 1 WLR 3869. The Judge referred to these payments as Payments 1 to 23, and we will do likewise. They run in date from early 2000 to 7 May 2008. All of t…”
“…Following a trial in January 2017, Marcus Smith J delivered a judgment on the issues: [2017] EWHC 677 (Ch); [2017] 1 WLR 3869. On issue 9A, he held that HMRC could not rely on section 320 of the Finance Act 2004 as a defence to repayment of tax paid before 8 Septemb…”