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The Clear Words of the Tax Statute

In the second of two linked articles Gordon Keenay of KPMG's Stamp Taxes Group examines the new focus on statutory interpretation from a practitioner's viewpoint
In last week's issue of The Tax Journal (30 January 2006 Issue 822) Rupert Shiers' article summarised the basic rules of statutory interpretation which in the post-BMBF1 world unequivocally apply to tax legislation. My aim in this article is to elaborate some further key themes which impact on day-to-day tax advice and interactions with HMRC.
Why is there a problem?
Many statutory provisions relating to tax are unclear — at least for some facts and circumstances. The process under which tax law is frequently amended adds to its...

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