“…The UT accepted that it was possible for the members of one partnership to become members of another partnership, citing Major v Brodie [1998] STC 491 (UT [28]) but that was not the automatic result (UT [30]). Rather, the position was summarised in Halsbury’s Laws of England (5th Ed) at p 111 which emphasised…”
“…Finally, I should mention that Mr Vaines referred us to, and placed considerable store by, the decision of Park J in Major v Brodie 70 TC 576, [1998] STC 491. Again, however, I do not consider that it helps Mr Vaines. It was a case on unusual facts, involving a Scottish partnership, and concerned different statutory…”