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Ramsay
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Ramsay
RAMSAY
Tax and the City review for May 2025
Zoe Andrews
Mike Lane
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).
Sajedi: an unwelcome Ramsay surprise
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
RBC: from the island of literal interpretation to the continental shelf
Kyle Rainsford
Victoria Hine
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Vaccine Research Limited Partnership and another v HMRC
Circular flow of funds not ‘income’
C Hoyle and others v HMRC
Sale of LLP capital accounts not subject to income tax.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
Ramsay revisited: six principles
Dominic Stuttaford
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).
Tax and the City review for June 2021
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Seven lessons from Clipperton
Oliver Marre
A recent tribunal decision provides lessons on the settlement provisions,
Ramsay
and piercing the corporate veil, writes barrister Oliver Marre
(5 Stone Buildings).
Avoidance outside tax: a new turn for Ramsay
Dominic Stuttaford
Sofia Casselbrant
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.
Go to page
of
2
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 20 June 2025
Treasury unveils agile approach to tax consultations
HMRC update on capital allowances guidance project
Private school fees VAT challenge fails
HMRC confirm extended deadline for final VAT return
CASES
Read all
Eastern Power Networks plc and others v HMRC
A Moffat and another v HMRC
Performance Leads Ltd v HMRC
Other cases that caught our eye: 20 June 2025
Nellsar Ltd v HMRC
IN BRIEF
Read all
Lessons from Moran on the TOAA rules
IHT excluded property settlements
HMRC’s updated DOTAS guidance
Tax and PISCES
Tax reform and the growth agenda
MOST READ
Read all
Other cases that caught our eye: 13 June 2025
Tax reform and the growth agenda
Solent Pathway Campus Ltd v HMRC
The new UK PE, TP and UTPP rules: key questions
The Government amendments to domestic Permanent Establishment rules