“…uin Record Shops Ltd [1980] 1 CMLR 669 at [11]; Fowler v HMRC [2020] UKSC 22, [2020] 1 WLR 2227 at [27]; and Szoma v Secretary of State for DWP [2005] UKHL 64, [2006] 1 AC 564 at [25]. Once Schedule 6 came into force, it was unnecessary to read the section 6 CA 2011 deeming provision into the tax law definition to achieve the purpose…”
“…hesis shall be carried as far as necessary to achieve the legislative purpose, but no further: Szoma v Secretary of State for Work and Pensions [2005] UKHL 64, [2006] 1 AC 564 at [25]. I do not consider that the deeming provision can override the legislative purpose of section 29 which was to prevent the commission of public nuisance…”