“…d by the FTT: Dreyfus v Inland Revenue Commissioners (1929) 14 TC 560, Memec Plc v Inland Revenue Commissioners [1998] STC 754 and HMRC v Anson [2015] UKSC 44, [2015] STC 1777. He said that the FTT had found that the general partner acted as trustee of the partnership assets (see FTT [135(4)], noting clause 18.4 again) and that Cayma…”
“… of the Vienna Convention on the Law of Treaties; and have been amplified by such cases as IRC v Commerzbank AG [1990] STC 285 and Anson v HMRC [2015] UKSC 44, [2015] STC 1777.…”