Dennis Dixon Senior Lawyer McGrigors and Patrick Cannon Tax Barrister 15 Old Square examine the distinction between the Halifax and Ramsay principles and asks how they may influence each other in the future
Halifax
Readers will recall that in Halifax Case C-255/02 [2006] STC 919 the ECJ decided that a supply of goods or services was still a 'supply' for VAT purposes even though it had been carried out solely in order to obtain a tax advantage. However the Court also held that Community law could not be relied upon for abusive ends. The Court defined 'abuse' as involving the obtaining of a tax advantage contrary to the purpose of the...
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Dennis Dixon Senior Lawyer McGrigors and Patrick Cannon Tax Barrister 15 Old Square examine the distinction between the Halifax and Ramsay principles and asks how they may influence each other in the future
Halifax
Readers will recall that in Halifax Case C-255/02 [2006] STC 919 the ECJ decided that a supply of goods or services was still a 'supply' for VAT purposes even though it had been carried out solely in order to obtain a tax advantage. However the Court also held that Community law could not be relied upon for abusive ends. The Court defined 'abuse' as involving the obtaining of a tax advantage contrary to the purpose of the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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