Limitation and conflict of laws: Axa Sun life plc and others v HMRC [2023] EWHC 944 (Ch) (26 April 2023) is one of those cases which makes virtually no sense when looked at in isolation: even those familiar with the background are likely to find it hard going. It is part of what can perhaps be best described as the interminable saga regarding certain corporation tax and ACT claims for periods dating back to the mid 1990s which have their origins in matters of compatibility of the UK legislation as it then stood with European Law. The courts have now been grappling with these issues for more than 20 years: this latest case deals with issues of limitation for making claims.
Here the High Court was required to determine three preliminary issues. The first was in respect of limitation and arose because of GLO procedure rules set out...
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")