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Well you can either have "JUDICIAL REVIEW – Claimant providing credit card handling services – claimant followed HMRC’s current published guidance and treated services as exempt from VAT – HMRC issued assessments on the basis that services were taxable – whether claimant had legitimate expectation that it would be taxed in accordance with the terms of the published guidance – if so whether HMRC entitled to resile from the guidance" or "HMRC seem to have been well and truly spanked here"
This seems a throwback to the approach to litigation of HMC&E as they were then . It was of course HMC&E who administered VAT. Is their legal team still autonomous?