“…y in isolation, but instead modify the effect of s.44. Thus s.44 must be read with the modifications made to it by s.45. As Lewison LJ said in DV3 RS LP v HMRC [2013] EWCA Civ 907; [2013] STC 2150 (“DV3”) at [20]:…”
“…to give effect to the purpose of the deeming provisions” (quoting from the judgment of Lewison LJ in DV3 RS Ltd Partnership v Revenue and Customs Commissioners [2013] EWCA Civ 907, [2013] STC 2150, at paragraph 22). As can be seen from the explanatory notes for what became the Finance Act 2005, section 91B was aimed at countering schemes…”