On 24 April 2020, the Court of Appeal rejected Rank’s attempt to circumvent the 4-year limitation period that had time-barred its earlier claims. Rank argued that HMRC should have brought Rank’s out-of-time claim into account when calculating other, earlier, in-time claims. However, on 23 February 2021, the UK Supreme Court refused Rank’s application for permission to appeal.
Source: monckton.com