In Stobart Group Ltd & Stobart Rail Ltd v Stobart & Tinkler [2019] EWCA (Civ) 1376, the Court of Appeal considered the extent to which valid notice had been given of a tax covenant claim prior to the expiry of the relevant limitation period. The Court of Appeal dismissed the appeal and upheld the original judgment, finding that valid notice had not been given for the purposes of the limitation period, but only for the purposes of the conduct provisions relating to potential tax covenant claims.