“…In his submissions on the scope of HMRC’s entitlement to form an opinion, Mr Ewart referred us to the decision of this Court in R (oao Haworth) v HMRC [2019] EWCA Civ 747, [2019] 1 WLR 4708. In that case the issue between the taxpayer and HMRC was whether the taxpayer was entitled to claim a tax advantage in respect of capital g…”