“…se on 17 February 2015, the Court of Appeal had handed down a ruling in Eclipse Film Partners No 35 LLP v Revenue and Customs Commissioners [2015] EWCA Civ 95, [2015] STC 1429 (‘Eclipse 35’). HMRC consider that that case shows that Mr Locke is not entitled to relief on the interest payments. There is no statutory right of appeal agai…”
“…s Court which delivered a judgment of the court (Sir Terence Etherton C, Christopher Clarke and Vos LJJ) dismissing the appeal: reported at [2015] EWCA Civ 95, [2015] STC 1429. The introductory paragraphs referred to the underlying purpose of the appeal:…”