The court was asked whether a scheme (SHIPS 2) for obtaining relief from tax was made up of a pre-ordained, composite, artifical and tax-motivated events and could be disregarded for fiscal purposes.
If there are lacunas in a statutory regime which enable tax avoidance, a purposive interpretation may not always remove them
Mummery, Thomas, Toulson LJJ
[2011] EWCA Civ 407, [2011] BTC 261, [2011] STI 1444, [2011] STC 1269
Bailii
Taxes Management Act 1970
England and Wales
Cited by:
Cited – Project Blue Ltd v Revenue and Customs SC 13-Jun-2018
The purchaser of land created a sub-sale and leaseback with bank so as to fund the purchase in a manner which would comply with Islamic finance principles. The Court was now asked whether purchaser or the bank were liable for stamp duty land tax on . .
Lists of cited by and citing cases may be incomplete.
Updated: 28 July 2021; Ref: scu.432651