VALUE ADDED TAX – decision on one issue in the appeals (interest) – amounts paid by
HMRC to appellants as bad debt relief under section 36 Value Added Tax Act 1994 – whether
interest should be paid on such amounts by HMRC from date of entitlement (rather than date
of claim) – section 78 Value Added Tax Act 1994 – error on the part of HMRC – invalid
statutory condition was not an error by HMRC – statements in HMRC Notices were errors
by HMRC – Found: statements in Notices were not the cause of outcomes required in s78(1)
– s78 not satisfied – EU law principles considered – appeal dismissed
Sources:
