Nigel Doran partner and Andrew Loan solicitor in the corporate tax group at Macfarlanes consider the Ramsay principle post-BMBF/SPI and look forward to the outcome of Campbell v IRC
When WT Ramsay Ltd v IRC[1981] STC 174 was first decided the principle to which it gave its name was said by the judges in the House of Lords to be a general principle of purposive statutory construction applied in a fiscal context. The principle was described by Lord Wilberforce in these terms (at page 179):
'There may indeed should ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Nigel Doran partner and Andrew Loan solicitor in the corporate tax group at Macfarlanes consider the Ramsay principle post-BMBF/SPI and look forward to the outcome of Campbell v IRC
When WT Ramsay Ltd v IRC[1981] STC 174 was first decided the principle to which it gave its name was said by the judges in the House of Lords to be a general principle of purposive statutory construction applied in a fiscal context. The principle was described by Lord Wilberforce in these terms (at page 179):
'There may indeed should ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
