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The Purpose of Legislation

Judy Harrison Senior Associate and Chris Bates Partner of Norton Rose LLP discuss two recent anti-avoidance cases Astall and Edwards v HMRC and Mayes v HMRC
There have been two recent cases which have considered whether it is possible to ignore steps inserted into transactions solely to obtain a tax advantage. Both of these cases involved high earners who wished to create a loss for tax purposes. In one case (Astall and Edwards v HMRC [2009] EWCA 1010) the court felt able to regard certain steps as being commercially irrelevant. In the other case (Mayes v HMRC [2009] EWHC 2443 (Ch)) the court did not feel able to disregard two steps even though they might be thought to have cancelled the economic effect of...

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