The Supreme Court have now issued their Order on the applications to appeal the Court of Appeal’s judgment in February

The Supreme Court has decided that it will hear now the appeals in relation to retrospective restriction of the limitation period (s107 FA 07 and 1320 of FA 04) and whether statutory error or mistake claims (s33 TMA) can be reconstructed to exclude restitution claims. All matters concerning the lawfulness of the DV Charge and aspects relating to the level at which tax is paid in a corporate group are to be referred now to the ECJ for a second ruling.