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A Word in Your Shell-Like

Adam Craggs solicitor with Reynolds Porter Chamberlain LLP (Tax Litigation team) discusses the Special Commissioners' decision in Shell UK Ltd v HMRC1
The recent decision of the Special Commissioners in Shell UK Ltd v HMRC [2007] STI 2122 will be of interest to those advisers who are concerned with the important issue of which materials may be taken into account when construing statutes.
Although the Commissioners were of the view that the statutory provisions under consideration were neither ambiguous nor obscure in ascertaining their purpose the Commissioners had regard to records of communications between taxpayers' representatives and the Government prior to enactment. It is this aspect of the decision which is commented upon below.
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