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Ramsay
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Ramsay
RAMSAY
Tax and the City review for May 2025
Zoe Andrews
Mike Lane
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
Kyle Rainsford
Victoria Hine
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
Zoe Andrews
Mike Lane
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).
Avoidance outside tax: a new turn for Ramsay
Dominic Stuttaford
Sofia Casselbrant
Sofia Casselbrant-Multala and Dominic Stuttaford (Norton Rose Fulbright) examine the Court of Appeal decision in
Rossendale
that demonstrates the potential general application of the
Ramsay
approach, but clearly shows its limits as a means of countering avoidance.
Go to page
of
2
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Tax Journal authors for April
HMRC issue Spotlight 63a on hybrid partnership property schemes
Government confirms that no SDLT charge for tenants on periodic tenancies
Unclaimed child trust funds
PIP awards: power to extend fixed-term awards introduced
CASES
Read all
HMRC v Burlington Loan Management DAC
HMRC v MR Currell Ltd
R Madsen v HMRC
Other cases that caught our eye: 1 May 2026
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
IN BRIEF
Read all
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
MOST READ
Read all
Centrica Energy Storage Ltd v HMRC
UK short-term business visitors: the Appendix 4 report
Clearwater Hampers Ltd v HMRC
Mega Marshmallows and the meaning of ‘normally’
Uncertain tax treatments consultation: extending uncertainty?