Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
Last month I wrote with Victoria Hine about the Supreme Court invoking the principle in WT Ramsay Ltd v IRC [1982] AC 300 (Ramsay) without it having been argued between the parties (‘RBC: from the island of literal interpretation to the continental shelf’ Tax Journal 7 March 2025). We expressed some surprise that the highest court in the land could say that the Ramsay principle was now mature and settled but appear to disagree on its scope and whether it could apply.
Following in its footsteps the First-tier Tribunal (FTT) has in Sajedi and others v HMRC [2005] UKFTT 297 (TC) (Sajedi) again invoked the principle where HMRC or the taxpayers did not raise it.
Background to the schemes
In 2016 Parliament...
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Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
Last month I wrote with Victoria Hine about the Supreme Court invoking the principle in WT Ramsay Ltd v IRC [1982] AC 300 (Ramsay) without it having been argued between the parties (‘RBC: from the island of literal interpretation to the continental shelf’ Tax Journal 7 March 2025). We expressed some surprise that the highest court in the land could say that the Ramsay principle was now mature and settled but appear to disagree on its scope and whether it could apply.
Following in its footsteps the First-tier Tribunal (FTT) has in Sajedi and others v HMRC [2005] UKFTT 297 (TC) (Sajedi) again invoked the principle where HMRC or the taxpayers did not raise it.
Background to the schemes
In 2016 Parliament...
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:
