“…Excise Commissioners, ECR I-1609, [2006] Ch 387, [2006] STC 919) and by the Court of Appeal in WHA Ltd v Revenue and Customs Commissioners [2007] EWCA Civ 728, [2007] STC 1695.…”
“…ly be to contribute to the working of the whole scheme, the effect of the whole scheme has also to be considered. In WHA Ltd v Customs and Excise Commissioners [2007] STC 1695, para 22, Lord Neuberger, delivering the leading judgment in the Court of Appeal, rejected the submission that the court was confined to considering the artifi…”