“…rcised in the UK, but Park J allowed an appeal ([2005] EWHC 547 (Ch), [2005] STC 789) and his decision was affirmed by the Court of Appeal ([2006] EWCA Civ 26, [2006] 1 WLR 1393).…”
“…Holden (Inspector of Taxes) [2006] STC 443, [2006] 1 WLR 1393 would justify the conclusion that the commissioners fell into this kind of error. I agree that their findings do not go so far as findings that the functions o…”