“…In Barclays Bank plc & Trustees of the Barclays Bank Pension Fund v HMRC [2007] EWCA Civ 442, [2008] STC 476 (“Barclays”), Arden LJ observed that the words “in connection with past service”, which appeared in s.612(1) of the Income and Corporation Taxes Act 1988, coul…”
“…ther of the cases on which he relies (Coventry and Solihull Waste Disposal Co Ltd v Russell [1999] 1 WLR 2093 and HMRC v Barclays Bank plc [2007] EWCA Civ 442, [2008] STC 476). On the contrary both those cases emphasise the protean nature of the phrase which takes it meaning from the context in which it is used: see Coventry at 2103…”