As you say, the public purse argument is now of very marginal use. This is namely the 'notional entitlement' possibility when (i) the error is due to a 'genuine mistake' (ii) that took place at the time of the claim, (iii) must involve a relationship change etc, and (iv) must surface as part of a compliance investigation.
Some hopeful souls still try to persuade HMRC to employ the pre-May 2007 version of these 'rules' (much more flexible) in cases that pre-date May 07 although I don't know if this works.
Are the maths behind the overpayment right? May still be in time to challenge the amount through an appeal/late appeal.
Is the client owed historical arrears, that can be rescued via s21 of the Tax Credits Act 2002? (where official error caused the error, and client was unaware etc... can go back 6 years etc). This could offset against the OP.
Failing all that, good luck with the COP 26 based challenge!
Steve
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