On 10 June the Court of Appeal published its decision in Sub-One v HMRC  EWCA Civ 773. The issue will be familiar to all readers and this note cannot purport to provide a comprehensive analysis of all of the arguments – indeed the Court of Appeal noted that it had been presented with eleven volumes of legislation and case law in order to enable it reach a conclusion on an ostensibly straight-forward issue.
This note will attempt to set out some of the most interesting issues in the appeal – and those with the broadest implication.
Please click to view the full case note onSub One v HMRC – The Court of Appeal
Please click to view the case note on the Upper Tribunal decision in Sub One v HMRC.