- Cited — Mainpay Limited v The Commissioners for His Majesty’s Revenue and Customs 2022-12-09
“…[2013] UKSC 24; [2013] 2 All ER 907. The UT recognised this approach in terms at UT [96], see paragraph 33 above, and their encapsulation of the approach was not subject to a…”
- Cited — Revenue And Customs v Fortyseven Park Street Ltd 2019-05-17
“…The contractual position is “the most useful starting point” (to use the words of Lord Reed in WHA Ltd v Revenue and Customs Commissioners [2013] UKSC 24, [2013] STC 943, at paragraph 27). The Manager cannot provide its services in pursuance of any contract with any Member since there has never been any such con…”
- Cited — Praesto Consulting UK Ltd v HM Revenue and Customs 2019-03-11
“…The most useful starting point is therefore the contractual position between the parties - Lord Reed in WHA Limited v Revenue and Customs Commissioners [2013] UKSC 24, [2013] STC 943 at [27].…”
- Cited — Adecco UK Ltd & Ors v The Commissioners for HMRC 2018-07-30
“…lationships and economic realities has been the subject of comment in several recent cases in the Supreme Court. In WHA Ltd v Revenue and Customs Commissioners [2013] UKSC 24, [2013] STC 943, Lord Reed commented (at paragraph 27):…”
- Cited — The Commissioners for HMRC v Newey (t/a Ocean Finance) 2018-04-17
“…and are likely to be conclusive unless shown to be inconsistent with underlying economic and commercial realities: see WHA Ltd v Revenue &Customs Commissioners [2013] UKSC 24, [2013] STC 943, at [27] per Lord Reed JSC, and Revenue & Customs Commissioners v Airtours Holidays Transport Ltd [2016] UKSC 21, [2016] STC 1509, at [47] per …”