Summary 

This appeal concerned a refusal by HMRC to pay to the appellant a repayment supplement pursuant to section VATA 1994, s 79 in respect of the appellant’s VAT return for accounting period 10/18. The appellant submitted a VAT return for period 10/18 in which a repayment of £71,170,729.68 was claimed. That amount represented the input tax incurred on the purchase of a property portfolio from Toys “R” Us Properties Limited (‘TRUP’) for the sum of £355,853,648.39 plus VAT. The appellant asked HMRC to set off the amount of its credit which corresponded to the amount of output tax TRUP would become liable to pay to HMRC. The sum of £71,084,816.43 was allocated by HMRC to TRUP’s VAT account and the remaining amount of £85,913.25 was authorised for repayment to the appellant. The appellant claimed repayment