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You are here: BAILII >> Databases >> United Kingdom Supreme Court >> Zipvit Ltd v Revenue and Customs (Respondent) (No 2) [2022] UKSC 12 (11 May 2022) URL: https://www.bailii.org/uk/cases/UKSC/2022/12.html Cite as: [2022] STI 793, [2022] WLR 2670, [2022] 1 WLR 2670, [2022] UKSC 12, [2022] BVC 8, [2022] STC 829, [2022] 4 All ER 607 |
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[2022] UKSC 12
On appeal from: [2018] EWCA Civ 1515
JUDGMENT
Zipvit Ltd (Appellant)
v
Commissioners for Her Majesty’s Revenue and Customs (Respondent) (No 2)
before
Lord Hodge
Lady Black
Lord Briggs
Lord Sales
Lord Hamblen
JUDGMENT GIVEN ON
11 May 2022
Heard on 29 and 30 January 2020
Roger Thomas QC
(Instructed by Mishcon de Reya LLP (London))
Respondent
Sam Grodzinski QC
Eleni Mitrophanous QC
(Instructed by HMRC Solicitor’s Office (Bush House))
LORD BRIGGS AND LORD SALES: (with whom Lord Hodge, Lady Black and Lord Hamblen agree)
Introduction
The principal issues of EU law
The factual background
(1) The “due or paid” issue
(2) The invoice issue
(3) The discretion issue
Conclusion