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Ramsay
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Ramsay
RAMSAY
Loopholes and tax avoidance
Kyle Rainsford
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.
Tax and the City review for May 2025
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).
Sajedi: an unwelcome Ramsay surprise
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
Kyle Rainsford
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Vaccine Research Limited Partnership and another v HMRC
Circular flow of funds not ‘income’
C Hoyle and others v HMRC
Sale of LLP capital accounts not subject to income tax.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
Ramsay revisited: six principles
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).
Tax and the City review for June 2021
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Seven lessons from Clipperton
Oliver Marre
A recent tribunal decision provides lessons on the settlement provisions,
Ramsay
and piercing the corporate veil, writes barrister Oliver Marre
(5 Stone Buildings).
Go to page
of
2
EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
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New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
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Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
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TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime