To QCB or not to QCB? Mark Brailsford and James Hamon (Berwin Leighton Paisner) review the judgment in Trigg on whether bonds were QCBs, and consider the wider impact on statutory interpretation.
Often when reviewing tax cases we must cast our mind back to unthinkably different times in order to understand properly the facts and circumstances at the time of the matters at hand. So just as we may find ourselves pondering the practicalities of transatlantic communication in the late-Victorian era when considering the formation of the principles of central management and control the Court of Appeal’s decision in Trigg v HMRC [2018] EWCA 17 Civ requires us to imagine a time when it was a very real possibility that the UK might abandon the pound and take up the euro.
Mr Trigg was a partner in a commercial partnership that sought to take advantage of a...
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To QCB or not to QCB? Mark Brailsford and James Hamon (Berwin Leighton Paisner) review the judgment in Trigg on whether bonds were QCBs, and consider the wider impact on statutory interpretation.
Often when reviewing tax cases we must cast our mind back to unthinkably different times in order to understand properly the facts and circumstances at the time of the matters at hand. So just as we may find ourselves pondering the practicalities of transatlantic communication in the late-Victorian era when considering the formation of the principles of central management and control the Court of Appeal’s decision in Trigg v HMRC [2018] EWCA 17 Civ requires us to imagine a time when it was a very real possibility that the UK might abandon the pound and take up the euro.
Mr Trigg was a partner in a commercial partnership that sought to take advantage of a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")