Market leading insight for tax experts
View online issue

HMRC v Altrad Services Ltd and another

In HMRC v Altrad Services Ltd and another [2024] EWCA Civ 720 (28 June) the Court of Appeal (CA) held that the correct purposive interpretation involved looking at the intention of the legislation as a whole rather than at a snapshot of each clause.

Altrad Services Ltd and Robert Wiseman and Sons Ltd took part in a marketed tax avoidance scheme designed to exploit the capital allowances rules applying in 2010 and 2011. (The law was subsequently amended by FA 2011 s 33 to make such arrangements ineffective.)

The scheme aimed to significantly increase the quantum of capital allowances available to the taxpayer companies via a sale and leaseback arrangement with a bank. The assets would be reacquired by the companies after a few weeks on the bank exercising a put option which each company had granted at the outset.

The intended outcome was that the companies would...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.