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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
Sample India’s 2025 GST Amendments
Test Samarth
1 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
2 /7
Understanding the FIG regime
Jo Bateson
3 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
4 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
5 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
6 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
7 /7
Sample India’s 2025 GST Amendments
Test Samarth
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
NEWS
Read all
Sample India’s 2025 GST Amendments
Test-Chancellor outlines financial services strategy
Test16/09/2025-Chancellor outlines financial services strategy
Test16/09/2025-Chancellor outlines financial services strategyAA
HMRC manual changes: 18 July 2025
CASES
Read all
Sample India’s 2025 GST Amendments
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
One minute with... Charlie Friend