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UBS and DB: a further victory for purposive legal interpretation

Philip Fisher (BDO) examines the recent Supreme Court ruling.

In our society a great deal of intellectual effort has been successfully devoted to tax avoidance. That could change significantly following the latest Supreme Court ruling in UBS AG v HMRC and DB Group Services v HMRC [2016] UKSC 13 (reported in Tax Journal 18 March 2016).
 

Background

Perhaps helpfully for younger readers Lord Reed who was speaking on behalf of and with the unanimous support of his distinguished colleagues opened his case summary by delivering a brief history lesson. He first explained (at para 1) how the tax legislation relating to share options restricted shares and various other concepts came about: 
 
‘The most sophisticated attempts of the Houdini taxpayer to escape from the manacles of tax (to borrow a...

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