Chris Bates (Norton Rose Fulbright) examines a decision which explores the scope of purposive construction of tax statutes and what constitutes a realistic view of the facts.
The First-tier Tribunal decision in Marathon Oil UK LLC (reported in Tax Journal 1 December 2017) casts some light on the arcane world of North Sea oil taxation. More importantly it explores the scope of the approach to statutory interpretation from Ramsay v IRC through Barclays Mercantile Business Finance Ltd v Mawson [2004] UKHL 57 to the recent decision involving Rangers Football Club (RFC 2012 Plc v Advocate General of Scotland [2017] UKSC 45).
Background to the case
Marathon Oil UK was a UK incorporated but UK tax resident company which was a participant and the operator of the Brae oil field in the UK sector of the...
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Chris Bates (Norton Rose Fulbright) examines a decision which explores the scope of purposive construction of tax statutes and what constitutes a realistic view of the facts.
The First-tier Tribunal decision in Marathon Oil UK LLC (reported in Tax Journal 1 December 2017) casts some light on the arcane world of North Sea oil taxation. More importantly it explores the scope of the approach to statutory interpretation from Ramsay v IRC through Barclays Mercantile Business Finance Ltd v Mawson [2004] UKHL 57 to the recent decision involving Rangers Football Club (RFC 2012 Plc v Advocate General of Scotland [2017] UKSC 45).
Background to the case
Marathon Oil UK was a UK incorporated but UK tax resident company which was a participant and the operator of the Brae oil field in the UK sector of 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:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")