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Court of Appeal decides HMRC’s deceit claim is time barred (IGE USA Investments LTD v Revenue and Customs Commissioners)

Court of Appeal decides HMRC’s deceit claim is time barred (IGE USA Investments LTD v Revenue and Customs Commissioners)
Published on: 21 April 2021
Published by: LexisPSL
  • Court of Appeal decides HMRC’s deceit claim is time barred (IGE USA Investments LTD v Revenue and Customs Commissioners)
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Article summary

Dispute Resolution analysis: By reason of section 36(1) of the Limitation Act 1980 (LA 1980), the six-year limitation period which had previously applied to actions at common law for deceit under section 3 of the Limitation Act 1623 should be applied by analogy to a claim for equitable rescission of a contract on the ground of fraudulent misrepresentation. Having made such finding, the Court of Appeal allowed the appeal of IGE USA Investments Ltd, formerly IGE USA Investments and entities in the GE group (GE), against a decision that no limitation period was applicable to HMRC's claim for equitable rescission of a contract on the basis of fraudulent misrepresentation. Written by Sandip Patel QC FCIArb, managing partner at Aliant, London. or take a trial to read the full analysis.

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