High Court of Justice Chancery Division

[2017] EWHC 677 (Ch)

The Honourable Mr Justice Marcus Smith

Judgment delivered 3 April 2017

Stamp duty reserve tax – 1.5% charge on issues to clearance services or in exchange for depositary receipts – Claim to restitution by way of mistake – Whether Finance Act 2004 (‘FA 2004’), s. 320 effective to abrogate the extended limitation period under Limitation Act 1980 (‘LA 1980’), s. 32(1)(c).

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