Market leading insight for tax experts
View online issue

The Ramsay Principle

In the first 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 the first of three articles on recent developments in the Ramsay principle I will be covering two post-BMBF/SPI cases in which the proper construction of legislation exploited for tax avoidance purposes was the central issue and a case in which a legalistic construction of the relevant legislation was held to exclude a Ramsay approach to the facts.
The decision in 2004 of the Appellate Committee of the House of Lords in BMBF Ltd v Mawson and IRC v Scottish Provident Institution...

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.