High Court allows an appeal by way of case stated from the decision of a taxation appeals commissioner, and determines the commissioner erred in refusing to designate the applicant's modified and imported vehicle as a "motor caravan", where the commissioners had placed too much emphasis on the ability of persons to move within the modified vehicle, but where the evidence suggested that it did comply with corresponding EU law.
Appeal by way of case stated - decision of taxation appeals commissioner - whether revenue commissioners correct as a matter of law in refusing to classify a vehicle owned by the appellant as a 'motor caravan' - vehicle purchased in UK and brought to jurisdiction where modifications subsequently made - EU framework for approval of motor vehicles for taxation purposes - relevant provisions of EU law - definition given to 'special purpose vehicles' - domestic law requirements - establishment, by the revenue commissioners, of specific additional requirements for registration of converted vehicles previously registered in another jurisdiction - material part of decision of appeal commissioner - inability to use kitchen facilities from within vehicle central to determination of taxation class - vehicle not significantly altered from its previous state - vehicle not a 'motor caravan' - whether an error in law - principles to be applied - particular definition adopted by appeal commissioner of 'living accommodation space' - no evidence to support finding that vehicle is not designed to accommodate movement of persons within vehicle - older statutory definition of 'motor caravan' - previous broad discretion to determine motor caravan status - three approaches to interpretation of EU law - literal, schematic and teleological - principle of legal certainty mitigates against commissioner's determination of status - misapplication of EU law principles - natural and ordinary meaning of 'motor caravan' - determination of appeals commissioner reversed - appellant's vehicle is a 'motor caravan' within the definition of domestic taxation legislation