PURPOSIVE-INTERPRETATION

With the recent decisions in Hurstwood Properties and Bostan Khan, the courts are again grappling with exactly what it means to construe statutory provisions purposively, writes Dominic Stuttaford (Norton Rose Fulbright).

Michael Conlon KC

A decade of tax decisions examined by Michael Conlon QC (Temple Tax Chambers).

Sofia Casselbrant

Dominic Stuttaford

Sofia Casselbrant-Multala and Dominic Stuttaford (Norton Rose Fulbright) examine the Court of Appeal decision in Rossendale that demonstrates the potential general application of the Ramsay approach, but clearly shows its limits as a means of countering avoidance.

Peter Vaines

Some good news and some bad news.

Michael Cullers

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including the latest proposals on tackling tax evasion and avoidance; the EU’s tax transparency measures; and recent cases illustrating the limits of the purposive approach.

Mark Middleditch

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

Mark Baldwin

George Cotterell

The wheels come off two SDLT planning schemes, but two charities fare better before the court. Mark Baldwin and George Cotterell examine the lessons learned from three recent SDLT decisions.