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Statutory Material Cited
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R (O) v Secretary of State for the Home Department
[2022] UKSC 3
Citation 1
…n" (para 32). More recently, this court has summarised the approach to statutory interpretation in R (O) v Secretary of State for the Home Department [2022] UKSC 3; [2023] AC 255. In that case, Lord Hodge, giving the majority judgment, stated (paras 29-31): "29. The courts in conducting statutory interpretation…
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Barclays Mercantile Business Finance Ltd v. HM Inspector of Taxes
[2004] UKHL 51
Citation 2
…s a clear understanding of the mischief which Parliament is addressing in a statutory provision. In Barclays Mercantile Business Finance Ltd v Mawson [2004] UKHL 51; [2005] 1 AC 684, in which the House of Lords clarified the principles underlying the so-called "Ramsay doctrine" by which sophisticated tax avoidanc…
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Fowler v Revenue and Customs
[2020] UKSC 22
Citation 3
…ent of statutory deeming provisions. The second is by reference to a purposive construction of section 32. In Fowler v Revenue and Customs Comrs [2020] UKSC 22; [2020] 1 WLR 2227, at para 27, this court summarised the applicable principles as follows: (1) The extent of the fiction created by a deeming provision i…
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Jetivia SA & Anor v Bilta (UK) Ltd & Ors
[2015] UKSC 23
Citation 4
…r the purposes of civil liability under section 213 it was appropriate to attribute Mr S's knowledge to the bank. In Bilta (UK) Ltd v Nazir (No 2) [2015] UKSC 23; [2016] AC 1 this court addressed a similar MTIC fraud in EUAs involving Bilta and counterparties who were a Swiss company, Jetivia SA, and its sole dir…