Fitzwilliam (Countess) and Others v Inland Revenue Commissioners: HL 9 Jul 1993

An Inheritance Tax avoidance scheme was valid. When testing whether a series of pre-ordained steps could be viewed as one artificial whole, it was not open to the Commissioners to pick and to choose which steps were to be counted. The exercise became artificial when some were excluded at the option of the commissioners. Pre-planning of steps alone not sufficient to attract Ramsay interpretation
References: Times 09-Jul-1993, Gazette 08-Dec-1993, Ind Summary 19-Jul-1993
Statutes: Finance Act 1975 Schedule 5

Last Update: 21 November 2020; Ref: scu.80587