Andrew Roycroft (Norton Rose Fulbright) considers the Upper Tribunal decision in Trigg and the interesting comments on the application of the Ramsay principle, particularly its application to closely articulated or prescriptive legislation.
Your monthly round-up of tax issues affecting the City, by Mark Middleditch (Allen & Overy).
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case
For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers
Jeff Webber answers a query on the tax issues when QCBs go bad.