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29. In order to discover the ambit of both the prohibition and its converse, a person’s authorisation, we must begin by reminding ourselves of the activity that is regulated. Immigration advice is defined inter alia as advice in relation to an individual, and immigration services means making representations on behalf of an individual. The notion of a practitioner–client relationship is clearly at the heart of the definition of the latter, and is obviously not alien to the former. 30. The next thing to note (and it is important for what follows) is that making representations is capable of being immigration services when the representations are made in correspondence with the government, that is to say representations can be made in writing. A question arises whether the use of the word ‘before’ in the definition as it relates to representations in civil proceedings has the effect of limiting the prohibition to oral process. We are confident that it does not have that effect. In the context of this regulatory scheme it would serve no useful purpose for there to be no regulation of written representations to a court or Tribunal on matters on which oral representations are regulated, and on which written representati ons to the government are regulated. The word “before” does not therefore mean ‘in the face of’: it is used simply to indicate that proceedings are on foot. 31. The conclusion that written representations are included within both the limbs of the definition of immigration services is, further, what one would expect from the structure of the definition, in which the phrase “the making of representations” occurs before the division between the two contexts in which such representations are regulated, one of those contexts certainly including written representations. 32. We now turn to s 82(2) which provides a definition of what is meant, for the purposes of the Act, by “ providing ” immigration advice or services. We are not primarily concerned with paragraph (b). We are concerned with paragraph (a), and we note that the wording is, mutatis mutandis, the same as that used in s 84(3A)(b). We will explore the consequences of that after looking at the present provision. 33. We observe as follows. First, the section does not use any wording suggesting a differentiation in the meaning of “providing” between providing immigration advice and providing immigration services. Secondly, the word “ person ” is used both of the provider and the object of the provision. The position of juridical persons is not perhaps clear; but what is clear is that there is no room for a suggestion that in the case (only) of immigration services the “ persons ” to whom the services are provided are, or include, a court or Tribunal, or the addressee of correspondence. That conclusion indeed also flows from the use of the word “ before ” rather than “to” in the definition of immigration services, to which we alluded above: the representations are made before the court or Tribunal, not to it. The service provided by a person providing immigration services is making a representation on behalf of an individual, and it is that individual, together possibly with others interested in the outcome of the case, to whom the service of representation is provided. We emphasise this because Mr Biggs submitted that the Tribunal should be regarded as the persons to whom the service is provided. We reject that submission. 34. Thirdly, the dash before the division of the definition into paragraphs (a) and (b) does not affect the continuous reading of the words used; the reference is to the provision of services “ by a person in the United Kingdom ” . The phrase “ in the United Kingdom ” must relate to the “ person ” : it cannot govern merely the word “ provision ” , because if it did it would conflict with the words in brackets, which clearly indicate that the destination (if we may so describe it) of the provision is irrelevant. If the relevant concept was “ provision in the United Kingdom ” in any sense implying that “ provision ” meant both giving and receiving, the words in the brackets would lose a great deal of their effect, because giving advice in (from) the United Kingdom to a person outside the United Kingdom would not be providing the service in the United Kingdom, so would not be regulated at all. 35. It follows that the s 84 prohibition on providing immigration services does not apply to their provision by a person who is not in the United Kingdom. That is exactly what might be expected as a matter of practicality, and of a scheme to which criminal sanctions are attached. If the provider of immigration advice or services is outside the United Kingdom, provision by that person is not regulated; on the other hand, provision of such services by a person who is in the United Kingdom is regulated, whichever part of the United Kingdom the person is in. A person in the United Kingdom who gives immigration advice to a person in China is the subject of regulation under Part 5; a person in China who gives immigration advice to a person in the United Kingdom is not regulated. The same is inevitably true for immigration services. A person in the United Kingdom who makes representations on behalf of a person in China is regulated; but a person in China who makes representations on behalf of a person is not regulated even if the person on behalf of whom the representations are made is in the United Kingdom. Mr Biggs’ post-hearing note suggests that that result cannot have been intended. In our view it must have been intended: otherwise, the Immigration Services Commissioner would have had the task of considering the authorisation of anybody, anywhere in the world, who proposed to write to the Tribunal or to an officer of the United Kingdom government about an immigration matter concerning a professional client; under the legislative scheme such a person would need qualification under s 84 before the letter or representation could be sent. 36. These observations clearly apply to written representations. Do they also apply to oral representations? There seems no good reason why they should not. We have seen that representations whether written or oral are within the regulatory scheme, and no distinction is drawn here or in the definition of immigration services between oral and written representations before a court or Tribunal. That means that, not surprisingly, a person in the United Kingdom who makes oral representations before a court or Tribunal in the United Kingdom is within the regulatory scheme but, slightly more surprisingly, a person who does so without being in the United Kingdom is not. The surprise, however, arises only from the potential difficulties of making oral representations to a court or Tribunal in the United Kingdom without oneself being in the United Kingdom. But it has not required the Covid-19 pandemic to show that such representations can be made by remote means; for many years the procedure rules and practice of various courts and tribunals have allowed proceedings to be conducted, or partly conducted, “by electronic means”. Once that difficulty is dealt with, it seems not at all surprising that the same regulatory rules should apply to oral representations as to written representations. If the person making them is outside the United Kingdom, the making of the representations before a court or Tribunal in the United Kingdom is not regulated. It is the geographical location of the person providing the advice or services that counts. 37. We can now look at the meaning of s 84(3A)(b), remembering that the phrasing is in all material respects the same as that in s 82(2)(a), no doubt intentionally so. It is likely to be difficult to see any good reason for thinking that any of the concepts dealt with in the one is different from that governed by the same wording in the other. Mr Biggs suggested that the key concern of the provision in s 84(3A) is “where the services are provided”. To an extent we agree. But it is not right to test that as he suggests by seeing what the meaning of the subsection would be if the words “by the person” were omitted, or to look at the words in this subsection in isolation. Instead, it is to be tested by comparison with the words of s 82(2). We have explained above why “ provision” there means giving, and cannot include the receiving, of the advice or service, and the same phrase must have the same meaning here. 38. But then the way forward is clear. It is, again, the geographical location of the person providing the immigration advice or services that counts. The authorisation by the designated qualifying regulator does not provide authorisation to “a person other than in England and Wales”: again, the location of the destination of the provision is irrelevant. 39. That means that an English barrister in England may provide immigration advice to a client in Scotland by writing, by telephone or by video link, and may make representations before the Tribunal on behalf of the Scottish client in writing or by “electronic means”. The barrister’s authorisation by the Bar Council does not, however, qualify the barrister to provide immigration advice or services outside England and Wales. If the barrister went to Scotland and made representations before the Tribunal in Scotland there would be a breach of s 84(1) unless the barrister had some further effective route to being a “qualified person” in Scotland, for example by registering with the Commissioner or obtaining authorisation from one of the designated professional bodies (as distinct from the designated qualifying regulators). 40. Mr Biggs submitted that it is absurd that as an English barrister he should be permitted to make representations from England but be prohibited from travelling to Scotland and making the same representations in the same forum there. It is not of course right to say that he is prohibited from so doing: the position is that the scheme of regulation to which he is subject, through the Bar Council and the Bar Standards Board does not, by deliberate statutory provision, extend outside England and Wales. Nothing prevents him seeking the appropriate authorisation if he wishes to operate in Scotland. But there are in any event oddities i n the scheme as it stands. There cannot be any doubt that those authorised in England and Wales by the designated qualifying regulators are subject to a restriction that does not apply to those authorised by the regulators for the rest of the United Kingdom. It is distinctly surprising that one way in which Mr Biggs could secure qualification to appear in Scotland would be by obtaining call to the Bar of Northern Ireland (and vice-versa). Evidently the effect of the passing of the Legal Services Act 2007 is that those qualified in England and Wales have lost the United-Kingdom-wide competence that they had before 2007 and which their colleagues from Scotland and Northern Ireland still share. As we have indicated above, it is very difficult to understand why that is so. It is not because of the need for authorisation to undertake a “reserved legal activity” under the 2007 Act. In relation to immigration advice, the activities regulated by Part 5 of the 1999 Act are not reserved legal activities within the meaning of the 2007 Act. In relation to immigration services, the activities regulated by Part 5 of the 1999 Act are not reserved legal activities within the meaning of the 2007 Act except in relation to a court (because sub - paragraphs 3(2) and 4(2) of Schedule 2 to that Act have the effect of excluding them in relation to tribunals). Further, immigration law is the same throughout the United Kingdom, and it is supervised by Tribunal s with jurisdiction over the whole United Kingdom. The provisions of s 84(3A)(b) ought to be reconsidered. But we have to interpret and apply them as they are. 41. If it be correct, as Mr Biggs submitted, that a barrister in England is not authorised to provide immigration services by appearing remotely from England before a Tribunal in Scotland, it would be equally the case that the barrister is not authorised to provide written representations in the same circumstances. But there is no Scottish immigration tribunal: the Immigration and Asylum Chambers of both the First-tier Tribunal and the Upper Tribunal operate throughout the United Kingdom and at any particular time a judge of either tribunal might be in any part of the United Kingdom, and working there. It cannot be the case that as a judicial file containing written submissions for consideration, or a judge dealing with such submissions, crosses the Tweed, the barrister making the submissions becomes prohibited by s 84(1) from doing so, and the Tribunal from treating the barrister as a representative. Apart from anything else, the barrister will not know what has happened, and it is not the barrister’s business to know. The advantage of the interpretation which we have adopted, and which we do anyway consider is the proper interpretation of the statutory provisions, is that as a barrister Mr Biggs knows the extent of his authorisation by knowing where he himself is. The authorisation is limited by something within the knowledge of the person providing the immigration advice or immigration services, not by something likely to be outside that person’s knowledge. 42. Mr Biggs also submitted that, in a hearing by remote means, the place where the tribunal is located should be decided by where certain administrative aspects of the hearing had been settled or initiated. That is wholly unviable. In fact First-tier Tribunal IAC hearings are administered in Scotland if the judge is going to sit in Scotland (or, we believe, in Northern Ireland), but Upper Tribunal hearings are administered from London. The actual video link is likely to be initiated in Scotland if the judge is in a hearing centre in Scotland, but that is all. There is, however, no reason why such a link could not be initiated from London, sending “joining instructions” to the parties and the judge (the latter being in a court in Scotland). Those arrangements would be outside the control of the parties and in all probability outside their knowledge. The question of conflict with s 84(1) and the more important issue of whether the appellant had representation, could not be left to be the casualties of administrative arrangements of this sort.