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.
Introduction
The decision in 2004 of the Appellate Committee of the House of Lords in BMBF Ltd v Mawson and IRC v Scottish Provident Institution...
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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.
Introduction
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 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:
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