- Cited — Duncan Campbell v NHS Business Services Authority 2023-11-16
“…atutory Interpretation, 8th ed at para 17.8. This is also consistent with the approach taken in the Supreme Court in Fowler v Revenue and Customs Commissioners [2020] 1 WLR 2227 to which Mr Schmitz referred us.…”
- Cited — Tradition Financial Services Ltd v Bilta (UK) Ltd & Ors 2023-02-10
“…The Supreme Court authoritatively stated the approach to statutory deeming provisions in Fowler v HMRC [2020] UKSC 22, [2020] 1 WLR 2227 at [27]:…”
- Cited — Inmarsat Global Limited v The Commissioners for HMRC 2022-07-28
“…t is sufficient, I think, to cite from the most recent of them, the decision of the Supreme Court in Fowler v Revenue and Customs Commissioners [2020] UKSC 22, [2020] 1 WLR 2227. Lord Briggs there said at paragraph 27:…”
- Cited — The Queen (on the application of D4) (notice of deprivation of citizenship) v Secretary of State for the Home Department 2022-01-26
“…In addition to these authorities which deal with notice and deemed notice, we were referred to Fowler v HMRC [2020] 1 WLR 2227, a case about a deeming provision in section 15 of the Income Tax (Trading and Other Income) Act 2005 (the case report was sent to us after the hearing and was…”
- Cited — The Queen (on the application of D4) (notice of deprivation of citizenship) v Secretary of State for the Home Department 2022-01-26
“…ovisions were provided for in the 2003 Regulations, both in their original form and as amended in 2018. I fully endorse what Lord Briggs said in Fowler v. HMRC [2020] 1 WLR 2227 at [27] to the effect that the extent of the fiction created by a deeming provision is primarily a matter of construction of the statute in which it appears (a…”
- Cited — Eynsham Cricket Club v Revenue & Customs 2021-02-23
“…effect of the deeming provision beyond its statutory purpose (Polydor Ltd v Harlequin Record Shops Ltd [1980] 1 CMLR 669 at [11]; Fowler v HMRC [2020] UKSC 22, [2020] 1 WLR 2227 at [27]; and Szoma v Secretary of State for DWP [2005] UKHL 64, [2006] 1 AC 564 at [25]. Once Schedule 6 came into force, it was unnecessary to read the sectio…”
- Cited — Revenue And Customs v Northumbria Healthcare NHS Foundation Trust 2020-07-10
“…thoritative consideration of the principles applicable to deeming provisions of this kind is the decision of the Supreme Court in Fowler v HMRC [2020] UKSC 22, [2020] 1 WLR 2227. Lord Briggs said at [27]:…”