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In HMRC v GMAC UK [2015] UKUT 0004 (5 January 2015) the UT affirmed its decision of 3 August 2012 and suggested that it would consider the implications of the BT decision in the course of the hearing of an application for leave to appeal.

Since the release of the UT’s 2012 decision HMRC had appealed to the Court of Appeal in relation to the preliminary issues decided by the UT in the BT appeal. The Court of Appeal had held that the UT had been wrong to hold that BT’s claim was not time barred in respect of supplies made between 1 October 1978 and 31 March 1989. BT had been refused permission to appeal to the Supreme Court. HMRC contended that the decision of the Court of Appeal in BT applied to GMAC while GMAC argued that such ‘read across’ was not possible due to...

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