Nigel Doran partner in the corporate tax group at Macfarlanes writes an extended 'Letter to the Editor' on EDI Services v HMRC
In their article View from 100 Parliament Street (The Tax Journal Issue 838 22 May 2006) HMRC reported on the Special Commissioners' decision in EDI Services Ltd v HMRC SpC 539 (EDI) which concerned the application of the Ramsay principle to an NIC avoidance scheme. Space constraints prevented HMRC from exploring in any detail the Special Commissioners' decision on the correct approach under the Ramsay principle to the facts of the case. However I think that that aspect of their decision merits further consideration as it is of vital importance to any practitioner advising on tax planning or avoidance.
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Nigel Doran partner in the corporate tax group at Macfarlanes writes an extended 'Letter to the Editor' on EDI Services v HMRC
In their article View from 100 Parliament Street (The Tax Journal Issue 838 22 May 2006) HMRC reported on the Special Commissioners' decision in EDI Services Ltd v HMRC SpC 539 (EDI) which concerned the application of the Ramsay principle to an NIC avoidance scheme. Space constraints prevented HMRC from exploring in any detail the Special Commissioners' decision on the correct approach under the Ramsay principle to the facts of the case. However I think that that aspect of their decision merits further consideration as it is of vital importance to any practitioner advising on tax planning or avoidance.
...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
