“…Mr Thornhill addressed further Barclays Mercantile Business Finance Ltd v Mawson (Inspector of Taxes) [2002] EWCA Civ 1853, [2003] STC 66(“Barclays Mercantile”) in which, at first instance, Park J had concluded that the relevant transaction was not a trading transaction because it was so heavily …”
“…[2003] STC 66, para 66, taxing statutes generally “draw their life-blood from real world transactions with real world economic effects”. Where an enactment is of that charac…”