“… adopted the Court of Appeal Criminal Division interpretation of “holding” in Tatham, were also referred to by this court in HMRC vPerfect [2019] EWCA Civ 465, [2020] STC 705.…”
“…The judgment which this Court gave on 19 March 2019 ([2019] EWCA Civ 465, [2020] STC 705) explains the history much more fully. This judgment supplements that one.…”