1. 7 Further,(www.Sentencedict.com) this principle should not be inapplicable simply because the citizen paid the money under mistake of law.

2. 22 According to Aegis, the breach of those principles consists in the fact that section 320, in excluding, without notice and retroactively, the limitation period for the Kleinwort Benson cause of action in relation to actions based on a mistake of law relating to a taxation matter under the care and management of the Commissioners, deprived it of the opportunity of making a claim which would otherwise have been made within the time-limits, thus rendering the exercise of the rights it derives under EU law excessively difficult or even impossible.