In July 2006, Mrs Potter took out a loan with Canada Square. At Canada Square's suggestion, Mrs Potter also took out insurance under a payment protection insurance policy (“the PPI Policy”). Mrs Potter was not told that over 95% of the premium for the PPI Policy was paid to Canada Square as its commission on the sale of the Policy (“the Commission”).
In December 2018, Mrs Potter issued a claim against Canada Square, to recover the sums that she had paid under the PPI Policy, plus interest. Canada Square argued that it was too late for Mrs Potter to bring this kind of claim, as section 9 of the Limitation Act 1980 imposed a six-year limitation period, which had long expired. Relying on section 32 of that Act, Mrs Potter argued that the six-year period did not begin to run until she found out about the Commission in 2018.
The County Court decided that section 32 of the Limitation Act 1980 applied and ordered Canada Square to pay Mrs Potter £7,953. Canada Square appealed, unsuccessfully, to the High Court and then to the Court of Appeal. Canada Square now appeals to the Supreme Court.

SKAT had paid refunds of Danish tax totalling £1.44 billion. The basis of its claims was the recovery of sums which had been wrongfully extracted from it by fraudulent misrepresentations orchestrated principally through entities based in England. The defendants were individuals and corporate entities who had procured the refund applications and received the bulk of the sums; they had never paid, or been liable to pay, the tax themselves. Many were domiciled in Brussels-Lugano Member States when the proceedings were served. Dicey Rule 3 provides that English courts had no jurisdiction to entertain an action for the enforcement, either directly or indirectly, of a penal, revenue or other public law of a foreign state.
                The Commercial Court determined as a preliminary issue that SKAT's claims fell within the scope of that rule and were therefore inadmissible. The judge concluded that seeking to recoup tax refunds erroneously paid was a claim directly or indirectly to enforce a foreign tax law and that although SKAT had framed its claims as private law causes of action, they were, in substance, claims to enforce Denmark's sovereign right to the tax in question. The respondent appealed to the Court of Appeal.
The Court of Appeal allowed the appeal, finding that a claim by the Danish tax authority to recover tax refunds said to have been induced by the fraudulent misrepresentations of entities based in England was a claim directly or indirectly to enforce a foreign tax law. The Danish tax authority, as a victim of fraud, sought only the restitution of monies of which it had been defrauded; its claims were therefore not inadmissible by virtue of the Dicey rule. The appellants now appeal to the Supreme Court.