“…This approach is not peculiar to the question whether an agreement creates a licence or a tenancy. In Secret Hotels 2 Ltd v HMRC[2014] UKSC 16, [2014] 2 All ER 685 the Supreme Court approved an observation of mine in an earlier case:…”
“…act does not fall within section 230(1)(b). After referring to Secret Hotels2 Ltd (formerly Med Hotels Ltd) v Revenue and Customs Commissioners [2014] UKSC 16, [2014] 2 All ER 685, she continued:-…”