“…o three years by the Finance Act 1997, without any possibility of extension for mistake. Following Fleming (t/a Bodycraft) v. Her Majesty’s Revenue and Customs [2008] UKHL 2, [2008] 1 WLR 195 (“Fleming”) s.121 Finance Act 2008 (“FA 2008”) disapplied the retrospective element of the three-year time limit for claims made before 1 Apr…”
“…stent with the principles of EU law established in Marks & Spencer, as subsequently applied by the House of Lords in Fleming v Revenue and Customs Commissioners[2008] UKHL 2, [2008] 1 WLR 195 (“Fleming”).…”