Jazztel Plc v HMRC

Sam Grodzinski QC acted for Jazztel (now Orange Spain Plc), instructed by PWC Legal, in a claim for repayment of Stamp Duty Reserve Tax that had been charged contrary to EU law. The claim was the leading case in a GLO, and raised issues concerning the validity of retrospective limitation periods in EU law; and the proper approach to determining whether tax had been paid under a mistake of law.