HMRC v Moorbury Limited [2010] UKUT 360 (TCC) (23 September 2010)
Redefinition of abusive transaction under Halifax principle – Taxpayer assessed to tax in respect of deductions wrongfully made in relation to the redefined transaction – Whether HMRC must subtract from the assessment the amounts of tax already paid – Whether HMRC may require the taxpayer to reclaim tax already paid as overpaid tax under s.80 VATA 1994