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 This appeal represents the third stage of the (thus far unsuccessful) endeavour by Shop Direct Group (“SDG”) to challenge the assessment to corporation tax of a very large repayment of VAT, together with an even larger amount of interest thereon, both of which were received by SDG on 19th September 2007. The repayment was £124,963,600 and the statutory interest thereon was £174,828,209. Both the repayment and the interest formed items in a series about which there were conjoined appeals by SDG and associated companies, within which they acquired the acronyms “VRP2” and “IP2”. They are however the only payments in the series in respect of which SDG has pursued its challenge to this court. I shall continue to use those acronyms, not least because they provide a useful link between this judgment, the Decision of the First-tier Tribunal (“FTT”) by Judge Berner and Miss O’Neill published on 14th February 2012 and the judgment of Asplin J in the Upper Tribunal (“UT”) released on 19th April 2013.