Elizabeth Small quoted in LexisPSL on the Supreme Court’s HMRC appeal judgment
Tax Partner, Elizabeth Small’s comments have been published in the LexisPSL article entitled ‘Supreme Court allows HMRC appeal in Test Claimants in the Franked Investment Income Group Litigation and others (Respondents) v Commissioners for Her Majesty’s Revenue and Customs (Appellant)’.
The article provides a detailed summary of the long-running proceedings associated with the Franked Investment Income (FII) Group Litigation (known as FIIGLO) and the ensuing judgment.
In her comments, Elizabeth looks at section 32(1)c of the Limitation Act 1980 with specific regard to HMRC appealing the Court of Appeal decision. Elizabeth further goes on to explain the impact of the judgment and how other potential changes in the law may influence future claims.
This article was first published in LexisPSL and can be accessed here (a subscription is required).