Many recent cases in the UK on tax avoidance schemes have contained the following citation from the judgment of Ribeiro PJ in the Hong Kong Final Court of Appeal in the case of Collector of Stamp Revenue v Arrowtown Assets Ltd (2004 ITLR 454):
Many recent cases in the UK on tax avoidance schemes have contained the following citation from the judgment of Ribeiro PJ in the Hong Kong Final Court of Appeal in the case of Collector of Stamp Revenue v Arrowtown Assets Ltd (2004 ITLR 454):
‘... the driving principle in the Ramsay line of cases continues to involve a general rule of statutory construction and an unblinkered approach to the analysis of the facts. The ultimate question is whether the relevant statutory provisions construed purposively were intended to apply to the transaction viewed realistically.’
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Many recent cases in the UK on tax avoidance schemes have contained the following citation from the judgment of Ribeiro PJ in the Hong Kong Final Court of Appeal in the case of Collector of Stamp Revenue v Arrowtown Assets Ltd (2004 ITLR 454):
Many recent cases in the UK on tax avoidance schemes have contained the following citation from the judgment of Ribeiro PJ in the Hong Kong Final Court of Appeal in the case of Collector of Stamp Revenue v Arrowtown Assets Ltd (2004 ITLR 454):
‘... the driving principle in the Ramsay line of cases continues to involve a general rule of statutory construction and an unblinkered approach to the analysis of the facts. The ultimate question is whether the relevant statutory provisions construed purposively were intended to apply to the transaction viewed realistically.’
As a...
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:
