- Cited — Banca Intesa Sanpaolo SpA & Anor v Comune Di Venezia 2023-12-13
“…[2020] UKSC 47; [2022] AC 1 (“…”
- Cited — BT Plc v The Commissioners for HMRC 2023-12-04
“… s.32(1)(c) Limitation Act 1980 and in any event the claim would be out of time under the test established in Test Claimants in the FII Group Litigation v HMRC [2020] UKSC 47, [2022] AC 1 (“FII 2020”) (the “9-month claim issue”).…”
- Cited — Saddiq Omar Abu Seedo v Fahmy El Gamal 2023-03-30
“…e leading case on when time starts running under s. 32(1) LA 1980 is now the decision of the Supreme Court in Test Claimants in the FII Group Litigation v HMRC [2020] UKSC 47 (“FII”). The specific question that arose was when time started running where the claim was for relief from the consequences of a mistake within s. 32(1)(c). T…”
- Cited — Alexander Gorbachev v Andrey Grigoryevich Guriev 2022-09-30
“…Similarly, in Test Claimants in the FII Group Litigation v HMRC [2020] UKSC 47, [2022] AC 1, Lord Reed and Lord Hodge said:…”
- Cited — Gemalto Holding BV & Ors. v Infineon Technologies AG & Ors. 2022-06-10
“…the so-called FII test adumbrated by the Supreme Court in a case concerning a mistake of law (Test Claimants in the Franked Investment Group Litigation v. HMRC [2020] UKSC 47 (FII)). The FII test suggests that time should begin to run from the point when the claimant knows, or could with reasonable diligence know, that it has a wort…”
- Considered — Bilal Ali (as personal representative of Farzand Ali (Deceased)) v Laith Khatib (as personal representative of Fateh Bubu (Deceased)) & Ors. 2022-04-08
“… on behalf of Dr Ali, accepted that the matter had not proceeded on this basis before the judge and that the point was new. He was referred to FII Group v HMRC [2020] UKSC 47, [2020] 3 WLR 1369, a case in which the Supreme Court considered the basis upon which the discretion to allow the withdrawal of a concession and new points to …”
- Cited — Jazztel Plc v The Commissioners for HMRC 2022-02-25
“…on simple contract within the meaning of section 5 of the Limitation Act 1980: see Test Claimants in theFII Group Litigation v Revenue and Customs Commissioners[2020] UKSC 47, [2022] AC 1, at [7] per Lord Reed PSC and Lord Hodge DPSC giving the judgment of the majority with which Lord Lloyd-Jones and Lord Hamblen JJSC agreed. We wil…”
- Cited — OT Computers Ltd v Infineon Technologies Ag & Anor 2021-04-14
“…Supreme Court in describing the rationale behind section 32(1)(c) in Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners [2020] UKSC 47, [2020] 3 WLR 1369 (‘FII’):…”
- Cited — Canada Square Operations Ltd v Potter 2021-03-11
“…ntly by the Supreme Court in describing the rationale behind section 32(1)(c) in Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners [2020] UKSC 47, [2020] 3 WLR 1369 (‘FII’):…”
- Cited — Revenue and Customs v News Corp UK & Ireland Ltd 2021-01-28
“…The most recent application of this principle is to be found in Franked Investment Income Group Litigation and others v HMRC [2020] UKSC 47, [2020] 3 WLR 1369, where there was a challenge to the correctness of the decision in Kleinwort Benson v Lincoln City Council [1999] 2 AC 349, which recognised…”