This was an appeal by the appellants against a decision by HMRC regarding the date interest was payable from. Until 1997, the UK legislation providing VAT refunds for bad debts contained a condition of entitlement (the property transfer condition) that, in a Court of Appeal decision in 2016, was found to be invalid under EU law principles. In 2007 and 2009, the appellants made claims for bad debt refunds on supplies made in the period 1989-1997 – the condition in question was not satisfied and for that reason, HMRC initially rejected the claims. HMRC eventually paid those bad debt refunds to the appellants in 2019. HMRC also paid interest on those refunds from the dates the refunds were claimed, on the basis that there had been an error on HMRC’s part in not paying the refunds upon the making of the claims. The issue in the hearing was whether HMRC should also have paid interest from earlier dates, being the dates when all