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Neutral Citation Number: [2020] EWCA Civ 1419
Case No: A3/2019/1656
Case No: A3/2019/1656
IN THE COURT OF APPEAL (CIVIL DIVISION)
ON APPEAL FROM THE UPPER TRIBUNAL
(TAX AND CHANCERY CHAMBER)
ON APPEAL FROM THE UPPER TRIBUNAL
(TAX AND CHANCERY CHAMBER)
Date: 29/10/2020
Before:
LADY JUSTICE KING
LORD JUSTICE NEWEY
and
LADY JUSTICE ANDREWS
LORD JUSTICE NEWEY
and
LADY JUSTICE ANDREWS
Between:
(1) TOTAL E&P NORTH SEA UK LIMITED
(formerly MAERSK OIL NORTH SEA UK LIMITED)
(2) TOTAL OIL UK LIMITED
(formerly MAERSK OIL UK LIMITED)
– and –
THE COMMISSIONERS FOR HER MAJESTY’S REVENUE AND CUSTOMS
(formerly MAERSK OIL NORTH SEA UK LIMITED)
(2) TOTAL OIL UK LIMITED
(formerly MAERSK OIL UK LIMITED)
– and –
THE COMMISSIONERS FOR HER MAJESTY’S REVENUE AND CUSTOMS