“…rpnale Ltd [1991] 2 AC 548 and Aspinalls Club Ltd v Revenue and Customs Commissioners, both in the Upper Tribunal, [2012] STC 2124, and in the Court of Appeal, [2014] STC 602.…”
“…the relevant cases such as Aspinalls Club Ltd v Revenue and Customs Commissioners, both in the Upper Tribunal at [2012] STC 2124, and in the Court of Appeal at [2014] STC 602 and Lipkin Gorman support this analysis and, in particular, that, contrary to the submissions of Mr Peretz QC, on behalf of HMRC, the decision of this court in…”