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HMRC v BT: reclaiming bad debt relief under the old scheme

Vinny McCullagh assesses the impact of HMRC’s victory at the Court of Appeal in HMRC v BT

The Court of Appeal has handed down its judgment in HMRC v British Telecommunications PLC [2014] EWCA Civ 433 which involved BT’s claim for bad debt relief on debts arising in the period from 1 January 1978 to 31 March 1989. This was an appeal from the Upper Tribunal where the discussion of the issues was focused largely on a claim made by GMAC but in substance the issues faced by BT and GMAC are the same. (The GMAC claim had an additional layer of complexity that was not required to be considered by the Court of Appeal in this case.)

The Upper Tribunal had ruled in favour of BT holding that not only...

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