[2013] UKUT 189 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

[The appeal against this decision is reported at [2014] BTC 11.]

Asplin J.

Decision released 19 April 2013.

Corporation tax – Receipts of payments in respect of overpaid VAT and statutory interest – Whether VAT repayments t/a receipts – Whether payments in respect of supplies made in discontinued trades chargeable to tax as post-cessation receipts – ICTA 1988, s. 103 and 106(2) – Whether payments in respect of interest taxable under Sch. D, Case III – Loan relationships rules – Whether a ‘money debt’ – FA 1996, s. 100