“…ents of David Richards LJ and myself in the then recent decision of the Court of Appeal in Rossendale Borough Council v Hurstwood Properties (A) Ltd and others [2019] EWCA Civ 364, [2019] 1 WLR 4567 (“Rossendale (CA)”). That was not, strictly speaking, a tax case, but it concerned an artificial and discreditable scheme to avoid the impos…”