John Watson and Preena Patani use the Kellogg decision to point a way forward for the development of tax in the UK
The appearance of a tax case like that of a fast moving particle depends upon the frame of reference of the observer. View the Kellogg decision ([2010] STC 925 CA) from a chair in a library surrounded by leather-bound copies of the law reports and you will find it unexceptional. The analysis is a straightforward interpretation of the statutory words.
Attempts to limit terms by reference to context are generally eschewed and although the Master of the Rolls portrayed some sympathy for the taxpayer’s contentions as to practical difficulties in identifying when companies are ‘connected’ the Court of Appeal did not allow that to deflect it from a literal approach. To those used to reading the older tax
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John Watson and Preena Patani use the Kellogg decision to point a way forward for the development of tax in the UK
The appearance of a tax case like that of a fast moving particle depends upon the frame of reference of the observer. View the Kellogg decision ([2010] STC 925 CA) from a chair in a library surrounded by leather-bound copies of the law reports and you will find it unexceptional. The analysis is a straightforward interpretation of the statutory words.
Attempts to limit terms by reference to context are generally eschewed and although the Master of the Rolls portrayed some sympathy for the taxpayer’s contentions as to practical difficulties in identifying when companies are ‘connected’ the Court of Appeal did not allow that to deflect it from a literal approach. To those used to reading the older tax
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:
