In the last of three articles Nigel Doran partner in the corporate tax group at Macfarlanes considers the development of the Ramsay principle since the seminal decision in BMBF/SPI
In my previous two articles (Issue 976 13 April 2009 and Issue 977 20 April 2009) I covered cases on the proper construction of legislation exploited for tax avoidance purposes on a legalistic construction of the relevant legislation and on loss creation schemes. In this final article I will cover post-BMBF/SPI cases on the Ramsay approach to schemes to avoid a receipt in the form of cash and cases on the application of the Ramsay approach to the construction of a document or instrument.
Broad and Realistic View of a...
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In the last of three articles Nigel Doran partner in the corporate tax group at Macfarlanes considers the development of the Ramsay principle since the seminal decision in BMBF/SPI
In my previous two articles (Issue 976 13 April 2009 and Issue 977 20 April 2009) I covered cases on the proper construction of legislation exploited for tax avoidance purposes on a legalistic construction of the relevant legislation and on loss creation schemes. In this final article I will cover post-BMBF/SPI cases on the Ramsay approach to schemes to avoid a receipt in the form of cash and cases on the application of the Ramsay approach to the construction of a document or instrument.
Broad and Realistic View of 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:
