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To Late to Claim?

Mark Whitehouse Rupert Shiers and Tom Mannion McGrigors review the recent High Court decision in Conde Nast and explore its relevance to the contentious use of time limits
Avid readers of The Tax Journal will recall that last month the House of Lords was asked to consider the question of appropriate forum for the claims by 306 groups of companies under the loss relief group litigation (Autologic Holdings plc and others v HMRC was heard by the Judicial Committee on 17 to 19 May 2005). The outcome in Autologic which is expected next month is set to determine whether claims for loss relief will be heard as appeals before the Special Commissioners or continue as argued by the taxpayer under the residual jurisdiction of...

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