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- Heading
- Introduction
- Background
- Grounds of appeal by hoopla
- Grounds 1 and 2 – interpretation and application of “party to”
- Coconut UT
- Parties’ submissions in outline
- Discussion
- Explanatory notes to Finance Bill 2012
- Ordinary meaning / OED definition
- Distinction between being “Party to” part of arrangements vs “party to” all of arrangements ?
- Ground 3 – payments to Entertainment in return for provision of services, as arm’s length commercial sub-contracting could not be amounts which “in the course of arrangements, [were] paid to or for th
- Conclusions