“… for charitable payments to overseas charities is another situation where HMRC are not required to exercise their rights in every case. Thus, in Routier v HMRC [2017] EWCA Civ 1584, this Court ( Arden LJ, Lord Briggs JSC and Green J) considered that the CJEU had held that such relief may properly be limited to payments to charities establ…”
“… States and between Member States and third countries”. It is common ground for the purposes of this appeal that the IOM is a third country: see Routier v HMRC [2017] EWCA Civ 1584.…”