“Claims for recovery of unlawfully exacted tax under the principle in Woolwich Equitable Building Society v Inland Revenue Comrs [1993] AC 70 (‘the Woolwich principle’) were not limited to those cases where there had been an actual demand by the revenue for payment, but applied generally in all cases where there had been a payment in response to an apparent statutory requirement to pay tax, which was not lawfully due.”
WLR Daily, 23rd May 2012
Source: www.iclr.co.uk