[2025] UKUT 00278 (TCC)

We have concluded that HMRC was correct to refuse repayment in each of the review decisions in issue in the present claims. To the (very limited) extent that we have identified an error in the reasoning in relation to the decision for Fluid Scotland, we are satisfied that it is highly likely that the same outcome would be reached if that error had not been made. Accordingly, the relief sought by the claimants is refused.