Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Brexit definition

What does Brexit mean? Brexit is the practical shorthand in legal drafting and advice for the United Kingdom’s withdrawal from the European Union and the legal, regulatory and trading changes flowing from it. It covers the UK’s cessation of EU membership on exit day (31 January 2020) and the cessation of the EEA Agreement’s application, the end of the implementation/transition period on IP completion day (31 December 2020), and the commencement, expiry or variation of post‑withdrawal trading and regulatory arrangements, including the UK‑EU Trade and Cooperation Agreement, the Windsor Framework (amending the Northern Ireland Protocol), and UK agreements with third countries...

Overpaid tax restitution: Woolwich and mistake claims, limitation, HMRC defences; VAT section 80 exclusivity, supplier/customer claims and Reemtsma

Published by a LexisNexis Tax expert

Practice notes

Practice Note

This Practice Note considers situations where a person has overpaid tax (that is, paid tax that was not in fact due) and their ability to recover that sum under the common law of restitution. It applies to both direct taxes and VAT and addresses the taxpayer’s rights to reclaim such amounts...

Direct taxes
VAT

Overpayments arise for a range of reasons, though a significant number of court cases have concerned tax charged in breach of EU law. A taxpayer should first determine whether they have, or previously had, a statutory route to recover overpaid tax, see Practice Note: Overpaid tax—the statutory regimes. If a statutory right exists, the terms of that legislation may bar a common law restitution claim, even where the statutory claim is now out of time...

This Practice Note cites EU-derived law and case authorities. The UK ceased to be an EU Member State on 31 January 2020. On that date, the UK entered an implementation period (IP) during which, for many purposes, it continued to be treated as a Member State and remained bound by EU law...

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Shanzé Shah

Old Square Tax Chambers

Shanzé is developing a busy and broad-ranging practice across all areas of tax law. She advises on both contentious and non-contentious matters, with particular experience in Inheritance Tax, Capital Gains Tax, Income Tax, VAT, SDLT, domicile and residence, the taxation of charities and trusts, and private client matters including wills.In 2025, Shanzé completed a secondment in the private wealth and tax team of a leading private client law firm, where she gained valuable experience advising high-net-worth individuals, trustees, and charitable bodies. Prior to specialising in tax, she worked at the Government Legal Department and gained legal experience across multiple jurisdictions, including China, India, Canada, and Greece. Shanzé is a member of the Attorney General’s Junior Junior Panel and has experience successfully appearing in court unled. She is regularly instructed in advisory work and litigation across a wide range of tax disputes and...

Web page updated on 21/05/2026

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