“…The point was also discussed by Mummery J in IRC v Commerzbank AG [1990] STC 285, 299, where he referred to the earlier decision of Avery Jones v IRC [1976] STC 290 in which Walton J had said (at pp.299–300):…”
“…hich they have been applied by the English courts is to be found in the judgment of Mummery J (as he then was) in Inland Revenue Commissioners v Commerzbank AG [1990] STC 285 at page 297 where the judge said:…”
“…iguous, it may be possible to resolve that ambiguity by giving a purposive construction to the convention looking at it as a whole by reference to its language [1990] STC 285 at 298 as set out in the relevant United Kingdom legislative instrument: per Lord Diplock (at 279).…”
“…ll-known. They are set out in articles 31 and 32 of the Vienna Convention on the Law of Treaties; and have been amplified by such cases as IRC v Commerzbank AG [1990] STC 285 and Anson v HMRC [2015] UKSC 44, [2015] STC 1777.…”