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Roderic Cordara QC and Paul Key, counsel, instructed by KPMG, chartered accountants, for the Appellant
Dr Paul Lasok QC and Hugh McNab, counsel, instructed by the Acting Solicitor for HM Revenue and Customs, for the Respondents
The question is therefore expressly divided between pre- and post-October 2003 periods. However, as became plain during the evidence, the concepts of "samples" and "gifts of small value" overlap, if, indeed, they do not coincide. It appears to us to be inherent in the wording of Article 5.6 that that is the case. Further, in our view it would make little sense if the two concepts were not considered together, and it was not made plain during the hearings that this was not the intention of the parties.
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Common Room
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