“…The House of Lords in Coventry Waste ([1999] 1 WLR 2093) dismissed the taxpayer’s appeal. Lord Hope emphasised the words “primary function” in the 1989 Order. Having discussed the legislative history and the implica…”
“…velop the point orally. I do not consider that it is supported by either of the cases on which he relies (Coventry and Solihull Waste Disposal Co Ltd v Russell [1999] 1 WLR 2093 and HMRC v Barclays Bank plc [2007] EWCA Civ 442, [2008] STC 476). On the contrary both those cases emphasise the protean nature of the phrase which takes it m…”