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RAMSAY


The application of Ramsay in a recent case and HMRC’s revised guidance on salaried members are among the topics covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
RBC reopens some old Ramsay uncertainties. Victoria Hine and Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Circular flow of funds not ‘income’
Sale of LLP capital accounts not subject to income tax.
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.
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).
The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
A recent tribunal decision provides lessons on the settlement provisions, Ramsay and piercing the corporate veil, writes barrister Oliver Marre (5 Stone Buildings).
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.
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