- Considered — Thomas William Good v The Commissioners of HM Revenue And Customs 2023-02-10
“…eracha v Miley. This was not, she suggested, a case where the arrangements cancelled themselves out unlike IRC v Scottish Provident Institution [2004] UKHL 52; [2004] 1 WLR 3172, for example. The Distribution Agreement had real consequences, namely the payment of the MAPs, and had to be considered alongside the Loan, Security Assignmen…”
- Cited — Khan v Revenue & Customs (Rev 1) 2021-04-30
“…pproach taken to the interpretation of “entitlement”, albeit in a different statutory context, in Inland Revenue Commissioners v Scottish Provident Institution [2004] 1 WLR 3172 at [19], and how that approach was described by Lord Reed JSC in UBS and others v Commissioners for HMRC [2016] 1 WLR 1005 at [71].…”
- Considered — Rossendale Borough Council v Hurstwood Properties (A) Ltd & Ors 2019-03-07
“…o Ltd 1982 SC (HL) 114, Furniss v Dawson [1984] AC 474, Carreras Group Ltd v Stamp Comrs [2004] STC 1377, Inland Revenue Comrs v Scottish Provident Institution [2004] 1 WLR 3172 and Tower MCashback LLP 1 v Revenue and Customs Comrs [2011] 2 AC 457. In each case the court considered the overall effect of the composite transaction, and c…”
- Cited — The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue And Customs 2019-02-06
“…case have to be seen in their context. In that respect, he relied on the decision of the House of Lords in IRC v Scottish Provident Institution [2004] UKHL 52, [2004] 1 WLR 3172, judgment in which was given on the same day as both judgment in Barclays Mercantile and the exercise by the Scottish Trustees of their put options. The scheme…”