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Abstract

[Extract]In a series of House of Lords decisions, commencing with the swinging judgments in WT Ramsay Ltd v IRC1 and followed by Furniss v Dawson,2 it was established that where there is a preordained transaction or series of transactions having steps inserted for no commercial purpose other than tax avoidance, those steps can be disregarded and the relevant statutory provision will be applied to the end result.

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