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Tax Case Round-Up 2004

Alan Dolton Editor of Tolley's Tax Cases and Tolley's VAT Cases surveys some of the leading direct tax decisions reached in 2004. The indirect tax round-up will be published in a forthcoming issue
The House of Lords issued an important decision in CIR v Scottish Provident Institution allowing the Revenue's appeal against the decision which the CS had reached in 2003. The HL unanimously held that 'it would destroy the value of the Ramsay principle of construing provisions such as (FA 1994 s 150A(1)) as referring to the effect of composite transactions if their composite effect had to be disregarded simply because the parties had deliberately included a commercially irrelevant contingency creating an acceptable risk that the scheme might not work as planned. We would be back in the...

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