“…The applicable law is authoritatively summarised by Lord Burrows in Tinkler v HMRC [2021] UKSC 39, [2022] AC 886 at [45], approving with minor modifications Briggs J’s summary of principle in HMRC v Benchdollar Ltd [2009] EWHC 1310 (Ch), [2010] 1 All ER 174. I have made t…”
“…There is no dispute about the applicable law which is authoritatively summarised by Lord Burrows in Tinkler v HMRC [2021] UKSC 39, [2022] AC 886 at [45], approving with minor modifications Briggs J’s summary of principle in HMRC v Benchdollar Ltd [2009] EWHC 1310 (Ch); [2010] 1 All ER 174. I have made t…”