CA-2024-001898 - [2025] EWCA Civ 1392

The amounts in issue

In the light of the subsequent determinations referred to above, it is common ground that Evonik’s overall claim as at 23 March 2016 (the date of payment by HMRC pursuant to the Summary Judgment Orders) can be broken down as follows:

Tax

Section 35A interest

Section 85 interest