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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> HBOS & Lloyds Banking Group v Revenue & Customs (VALUE ADDED TAX - decision on one issue in the appeals (interest)) [2021] UKFTT 307 (TC) (04 September 2021)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08249.html
Cite as: [2021] UKFTT 307 (TC)
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| Decision Number: | TC 08249 |
| Appellant: | HBOS & Lloyds Banking Group |
| Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
|
Chairmen / Special Commissioners: |
Zachary CITRON |
| Date Of Decision: | 04/09/2021 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | 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 |