- Cited — Revenue And Customs v Fortyseven Park Street Ltd 2019-05-17
“…The contractual position is “the most useful starting point” (to use the words of Lord Reed in WHA Ltd v Revenue and Customs Commissioners [2013] UKSC 24, [2013] STC 943, at paragraph 27). The Manager cannot provide its services in pursuance of any contract with any Member since there has never been any such contract. In contra…”
- Cited — Praesto Consulting UK Ltd v HM Revenue and Customs 2019-03-11
“… useful starting point is therefore the contractual position between the parties - Lord Reed in WHA Limited v Revenue and Customs Commissioners [2013] UKSC 24, [2013] STC 943 at [27].…”
- Cited — Adecco UK Ltd & Ors v The Commissioners for HMRC 2018-07-30
“…economic realities has been the subject of comment in several recent cases in the Supreme Court. In WHA Ltd v Revenue and Customs Commissioners [2013] UKSC 24, [2013] STC 943, Lord Reed commented (at paragraph 27):…”
- Cited — The Commissioners for HMRC v Newey (t/a Ocean Finance) 2018-04-17
“…o be conclusive unless shown to be inconsistent with underlying economic and commercial realities: see WHA Ltd v Revenue &Customs Commissioners [2013] UKSC 24, [2013] STC 943, at [27] per Lord Reed JSC, and Revenue & Customs Commissioners v Airtours Holidays Transport Ltd [2016] UKSC 21, [2016] STC 1509, at [47] per Lord Neuberger P…”