Lloyd's Maritime and Commercial Law Quarterly


Alexander YS Georgiou*

Prudential Assurance v HMRC


In Prudential Assurance Co v HMRC,1 their Lordships performed a stunning volte-face in the law of unjust enrichment, expressly departing from the decision in Sempra Metals Ltd v IRC,2 reached by the House of Lords only 11 years earlier. This note seeks critically to examine the reasoning underpinning that remarkable reversal.
The decision in Prudential is the latest blow in the litigation which has spawned from the “Franked Investment Income” taxation scheme. The basic facts, though somewhat technical, are by now a familiar sight. Pursuant to the Income and Corporation Taxes

Case and comment


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