“…venue. At first instance, the Commissioners found the facts (taken from the summary in the judgment of Sir Nicholas Browne-Wilkinson VC in the Court of Appeal, [1991] 1 WLR 341 at p.349) as follows:…”
“…was in the words of Sir Nicolas Browne-Wilkinson V-C “merely a device to secure a fiscal advantage or a genuine trading activity”. Earlier in his judgment (see [1991] 1 WLR 341 at page 355) the Vice-Chancellor had said:…”