“…the reasoning in R vBajwa [2012] 1 WLR 601, R vTaylor & Wood [2013] EWCA Crim 1151 and R v PhilipTatham [2014] EWCA Crim 226 is based on a domestic law analysis which recognises that under English law a…”
“… authorities also support the conclusion that the time at which the excise duty point arises is relevant. HMRC v Jacobson [2018] UKUT 0018 (TCC) and R v Bawja [2012 1 WLR 601 also support that proposition in general terms.…”