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Before the PBR, it was rumoured that an attempt might be made to limit
the cost of claims for compound interest resulting from HMRC breaches of
taxpayers’ European law rights. Fortunately, these rumours have proved to be
unfounded, at least as far as the PBR is concerned. However, in the
consultation document “Tax Appeals Against Decisions Made by HMRC” it is
suggested that the circumstances in which interest should be paid and the
rate at which it should be paid should be laid down by Parliament rather
than determined at the discretion of the VAT Tribunal.
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