In the second 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 first article (Issue 976 13 April 2009) I covered cases on the proper construction of legislation exploited for tax avoidance purposes and a case on a legalistic construction of the relevant legislation. In this second article I will cover the Ramsay approach to the facts and in particular to composite transactions in the context of post-BMBF/SPI cases relating to loss creation schemes.
Broad and Realistic View of a Combination of Acts Forming a Composite Whole
...
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In the second 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 first article (Issue 976 13 April 2009) I covered cases on the proper construction of legislation exploited for tax avoidance purposes and a case on a legalistic construction of the relevant legislation. In this second article I will cover the Ramsay approach to the facts and in particular to composite transactions in the context of post-BMBF/SPI cases relating to loss creation schemes.
Broad and Realistic View of a Combination of Acts Forming a Composite Whole
...
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:
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