“…arnwath also quoted from, and endorsed, the guidance given by Sales J (as he then was) in Eclipse Film Partners (No.35) LLP v Revenue and Customs Commissioners [2014] STC 1114 at [96], where he “likened the correct approach to statutory interpretation to that appropriate to a consolidation statute (as explained by the House of Lords …”
“…In Eclipse Film Partners (No 35) LLP v HMRC[2013] UKUT 639 (TC), [2014] STC 1114 Sales J (as he then was) considered the approach to construction of a consolidating statute such as ITA 2007:…”
“…Eclipse 35 appealed to the Upper Tribunal where the appeal was dismissed by Sales J (as he then was). His decision is reported at [2013] UKUT 639 (TCC), [2014] STC 1114. He also recognised that the appeal focused solely on the trading issue because it was only if Eclipse 35 carried on a trade that important tax advantages woul…”
“…ord Carnwath, at [9] and [10], endorsed the guidance given by Sales J (as he then was) in Eclipse Film Partners (No 35) LLP v Revenue and Customs Commissioners [2014] STC 1114 at [96], where Sales J had likened the correct approach to that appropriate to a consolidation statute (as explained by the House of Lords in Farrell v Alexand…”