“…sider whether it is excluded by section 22(1)(b): see the decision of this court in Revenue and Customs Commissioners v SSE Generation Ltd [2021] EWCA Civ 105, [2021] STC 369. Accordingly, neither side has founded any arguments before us on the provisions of section 22.…”
“…trenching the effect of those decisions and of established Revenue practice: see the comments of Rose LJ (as she then was) in the SSE case [2021] EWCA Civ 105, [2021] STC 369, at [19], and the decision of the UT (Judges Herrington and Brannan) in that case, [2019] UKUT 332 (TCC), [2020] STC 107, at [66].…”