Andrew Roycroft (Norton Rose Fulbright) considers the Upper Tribunal decision in Trigg and the interesting comments on the application of the Ramsay principle, particularly its application to closely articulated or prescriptive legislation.
With the ‘Brexit’ debate in full swing the Upper Tribunal (UT) decision in HMRC v Trigg [2016] UKUT 0165 (TCC) takes us back to a very different time. In the late 1990s the burning issue was not whether the UK should leave the EU but whether it should adopt the euro. Closer union rather than exit was considered a realistic possibility.
Just as now politicians and business leaders debated the issues and lawyers sharpened their pencils to draft for the possible consequences of a historic event. One point of debate was whether to include provisions in loan notes setting out what would happen in the...
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Andrew Roycroft (Norton Rose Fulbright) considers the Upper Tribunal decision in Trigg and the interesting comments on the application of the Ramsay principle, particularly its application to closely articulated or prescriptive legislation.
With the ‘Brexit’ debate in full swing the Upper Tribunal (UT) decision in HMRC v Trigg [2016] UKUT 0165 (TCC) takes us back to a very different time. In the late 1990s the burning issue was not whether the UK should leave the EU but whether it should adopt the euro. Closer union rather than exit was considered a realistic possibility.
Just as now politicians and business leaders debated the issues and lawyers sharpened their pencils to draft for the possible consequences of a historic event. One point of debate was whether to include provisions in loan notes setting out what would happen in the...
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:
