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HMRC’s Ground 2
HMRC’s Ground 2
Ground 2 of HMRC’s appeal poses the question whether the amounts which have been repaid were amounts determined as payable by HMRC in respect of an appeal under section 83(b)? In the light of our conclusion in respect of Ground 1, it is strictly unnecessary to consider HMRC’s Ground 2) but since it was fully argued before us, we shall express our views in outline.
- Heading
- Contents
- Introduction
- Factual background
- Statutory provisions relating to the payment of additional interest
- The issues before the FTT
- The decision – the section 80 objection
- The decision – post April 2009 objection
- Grounds of appeal
- The Company’s Grounds of Appeal
- The section 80 objection - submissions (in outline) and discussion
- HMRC’s Ground 1 – The Company’s submissions
- Discussion – HMRC’s Ground 1
- HMRC’s Ground 2
- HMRC’s Ground 2 – HMRC’s submissions
- HMRC’s Ground 2 – The Company’s submissions
- Discussion – HMRC’s Ground 2
- The Company’s appeal
- The Company’s Ground 1 – the Company’s submissions
- The Company’s Ground 1 – HMRC’s submissions
- Discussion – the Company’s Ground 1
- The Company’s Ground 2: post-April 2009: EU law
- The Company’s Ground 2 – the Company’s submissions
- The Company’s Ground 2 – HMRC’s submissions
- Discussion – The Company’s Ground 2
- The Company’s Ground 3 –The Company’s submissions
- The Company’s Ground 3: HMRC’s submissions
- Discussion: The Company’s Ground 3
- Conclusions