Following the recent settlement of HMRC v IGE USA Investments (featured by ITR EMEA Tax Awards 2021 as one of their ‘Impact Cases of the Year’) Gareth Tilley and Max Marenbon consider whether rescission of a contract for fraudulent misrepresentation in equity carries a limitation period by analogy with the tort of deceit (on which question leave was granted to appeal to the Supreme Court in the HMRC case).

Philip Jones QC, Gareth Tilley and Max Marenbon acted on behalf of HM Revenue & Customs.

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