Generate a structured brief — facts, issues, held, reasoning, and significance — for this case in seconds. Or browse the verbatim judgment via the source links below.
LORD JUSTICE GROSS LORD JUSTICE LEWISON and LORD JUSTICE UNDERHILL ____________________
Jonathan Peacock QC and Michael Ripley (instructed by PricewaterhouseCoopers Legal LLP) for the Appellant Julian Ghosh QC and Ms Barbara Belgrano (instructed by HMRC Solicitors Office) for the Respondent Hearing date: 1st July 2014 ____________________
Subject to the exceptions, immaterial for present purposes, contained in sub-section (2), s.130 continues as follows:
The FTT considered (at [43]) that this construction was supported by the context, by s.84(2)(a)'s "discernible purpose" and by the wording of s.84(2) as a whole. The relevant time was when the profit accrued (at [46]). S.84(2)(a) did not look to the end result.
The arrangements in the present case did not accord with the circumstances to which s.84(2)(a) was directed. The UT thus agreed with HMRC (at [30]):
Auto-extracted from BAILII. Full structured brief in progress — the source links below give you the verbatim judgment in the meantime.
Multiple official and mirror sources — pick whichever loads cleanly on your network.
[2026] EWCA Civ 31
Common Room
0 comments · About the Common Room →
No comments yet — start the discussion.
Voted-best comments help future students and feed Caselaw's AI study tools.