- Cited — BT Plc v The Commissioners for HMRC 2023-12-04
“…It was confirmed in Test Claimants in the FII Group Litigation v Revenue and Customers Commissioners [2012] UKSC 19, [2012] 2 AC 337 (“FII 2012”) that in order to fall within s.32(1)(c), the mistake must constitute an essential element of the cause of action (see also FII 20…”
- Cited — Jazztel Plc v The Commissioners for HMRC 2022-02-25
“… of action, and not merely form part of the context”: ibid, at [14], referring to Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners[2012] UKSC 19, [2012] 2 AC 337 (“FII (SC) 1”).…”
- Cited — Lone v London Borough of Hounslow 2019-12-17
“…In another case cited later by Prof Burrows, Test Claimants in the FII Group Litigation v Revenue Customs Commissioners [2012] UKSC 19, [2012] 2 AC 337, Lord Sumption stated at [204]:…”
- Cited — Revenue And Customs v Coal Staff Superannuation Scheme Trustees Ltd 2019-10-03
“…Furthermore, in Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners [2012] UKSC 19, [2012] 2 AC 337 Lord Sumption held at paragraph 176 that:…”
- Explained — FMX Food Merchants Import Export Co Ltd v HM Revenue and Customs 2018-10-30
“…The principle of legal certainty was considered by the Supreme Court in Test Claimants in the Franked Investment Income Group Litigation [2012] UKSC 19; [2012] 2 AC 337. Lord Walker of Gestingthorpe JSC explained at [93] to [95] that it is well established that EU law has no general objection to the provision …”
- Cited — Evans & Anor v South Wales Police 2018-10-02
“…e limitation period was possible, in view of the decision of the Supreme Court in Test Claimants in theFII Group Litigation v Revenue and Customs Commissioners [2012] UKSC 19, [2012] 2 AC 337; and (c) that the claims were accordingly confined to the period of six years prior to the issue of proceedings.…”