Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case