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Is Stamp Taxes Planning Dead?

 
Steven McGrady Partner KPMG's Stamp Taxes Group considers the issues facing the stamp taxes planner
 
The aim of this article1 is to offer the professional adviser some practical guidance concerning the implications of the case law on avoidance for stamp taxes planning. In other words the subject is: what do the cases on the Ramsay principle tell us about whether or not stamp taxes planning will work?
Scope of Ramsay
 
There is a threshold issue which is that as a general matter the scope of the Ramsay doctrine is controversial. To preempt argument about this and for the purposes of this article I shall take the Ramsay principle to be a rule...
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