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The Company’s Ground 3: HMRC’s submissions
The Company’s Ground 3: HMRC’s submissions
HMRC submitted that whether, and if so at what rate, to award additional interest under s. 84(8) were matters for the FTT in the exercise of its discretion.
- 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