Philip Ridd considers the slippery notion of legislative intent in the context of tax avoidance and suggests if tangentially that Furniss v Dawson[1984] STC 153 needs yet more reconsideration
Many moons ago a Minister observed cheerily during a meeting that he had taken out a mortgage on his home solely to secure tax relief and he supposed that the Revenue would say that that was tax avoidance. The two Head Office officials both Inspectors of Taxes hastened to assure him in the negative. The third official a lawyer took the opposite view but maintained a dignified or cowardly silence. The lawyer later ingested a generous slice of humble pie upon reading Challenge Corporation Ltd v Commissioner of Inland Revenue[1987] AC 155...
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Philip Ridd considers the slippery notion of legislative intent in the context of tax avoidance and suggests if tangentially that Furniss v Dawson[1984] STC 153 needs yet more reconsideration
Many moons ago a Minister observed cheerily during a meeting that he had taken out a mortgage on his home solely to secure tax relief and he supposed that the Revenue would say that that was tax avoidance. The two Head Office officials both Inspectors of Taxes hastened to assure him in the negative. The third official a lawyer took the opposite view but maintained a dignified or cowardly silence. The lawyer later ingested a generous slice of humble pie upon reading Challenge Corporation Ltd v Commissioner of Inland Revenue[1987] AC 155...
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