20 November 2020

Test Claimants in the Franked Investment Income Group Litigation v HMRC; SC

This appeal concerns the correctness of two of the most important decisions on the law of limitation of recent times: the decisions of the House of Lords in Kleinwort Benson Ltd v Lincoln City Council [1999] 2 AC 349 (“Kleinwort Benson”) and Deutsche Morgan Grenfell Group plc v Inland Revenue Comrs [2006] UKHL 49; [2007] 1 AC 558 (“Deutsche Morgan Grenfell”). It arises in the course of long-running proceedings known as the Franked Investment Income (“FII”) Group Litigation.

Of Pump Court Tax Chambers: David Ewart QC, Elizabeth Wilson and Barbara Belgrano. Of Brick Court Chambers: Jennifer MacLeod and Frederick Wilmot-Smith. Counsel instructed by HMRC Solicitors Office for the Appellant.

The full Judgment can be read here.