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  • I'd say it goes further than HMRC's view though - it's the law

    It's the law but it has to be interpreted and applied by a court, not by HMRC. They obviously have their view but they have lost high profile cases on this in the past.

  • I think we agree - my point was about what the law is (i.e. as a court should decide) and that this definition of avoidance wasn't just an HMRC opinion but had backing in law itself

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