![UT-2024-000123 - [2025] UKUT 00360 (TCC)](https://backend.juristeca.com/files/emisores/logo_ICfrj4g.png){kind=logo}
The Company’s Ground 2: post-April 2009: EU law
The Company’s Ground 2: post-April 2009: EU law
Again, in the light of our decision on HMRC’s Ground 1, it is unnecessary for us to consider the Company’s Ground 2, and we formally dismissed the Company’s appeal on this Ground. However, we summarise below the reasons why we would have dismissed the Company’s appeal on Ground 2 in any event.
- 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