Market leading insight for tax experts
View online issue

The Ramsay Principle

 
 
In the last of three articles Nigel Doran partner in the corporate tax group at Macfarlanes considers the development of the Ramsay principle since the seminal decision in BMBF/SPI
 
In my previous two articles (Issue 976 13 April 2009 and Issue 977 20 April 2009) I covered cases on the proper construction of legislation exploited for tax avoidance purposes on a legalistic construction of the relevant legislation and on loss creation schemes. In this final article I will cover post-BMBF/SPI cases on the Ramsay approach to schemes to avoid a receipt in the form of cash and cases on the application of the Ramsay approach to the construction of a document or instrument.
Broad...

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:

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 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top