RAMSAY

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.

Mike Lane

Zoe Andrews

The application of Ramsay in a recent case and HMRC’s revised guidance on salaried members are among the topics covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.

Victoria Hine

Kyle Rainsford

RBC reopens some old Ramsay uncertainties. Victoria Hine and Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.

Loan charge determinations upheld as Ramsay requires genuine economic cost

Circular flow of funds not ‘income’

Sale of LLP capital accounts not subject to income tax.

Oliver Marre

Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.

Dominic Stuttaford

With the recent decisions in Hurstwood Properties and Bostan Khan, the courts are again grappling with exactly what it means to construe statutory provisions purposively, writes Dominic Stuttaford (Norton Rose Fulbright).

Mike Lane

Zoe Andrews

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

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