“…s LJ and myself in the then recent decision of the Court of Appeal in Rossendale Borough Council v Hurstwood Properties (A) Ltd and others [2019] EWCA Civ 364, [2019] 1 WLR 4567 (“Rossendale (CA)”). That was not, strictly speaking, a tax case, but it concerned an artificial and discreditable scheme to avoid the imposition of non-domest…”
“…e referred us to a decision of this court in Rossendale Borough Council v Hurstwood Properties (A) Limited and Ors, Wigan Council v Property Alliance Group Ltd [2019] 1 WLR 4567 and to R (on the application of Principled Offsite Logistics) v Trafford [2018] EWHC 1687 (Admin). In my judgment, neither case assists him and even if they di…”