Where there existed properly constituted documents recording a contract, the court could not go behind them to discover the real transaction. The rules in Ramsay is not a special set of principles restricted to issues in determining the legal effect for taxation of a series of transactions, but rather part of general rules. In this case no steps had been introduced into the transaction whose only purpose was to reduce tax liability, and they could not be seen as one composite whole.
Citations:
Times 14-Nov-2000, Gazette 23-Nov-2000
Jurisdiction:
England and Wales
Citing:
Cited – W T Ramsay Ltd v Inland Revenue Commissioners HL 12-Mar-1981
The taxpayers used schemes to create allowable losses, and now appealed assessment to tax. The schemes involved a series of transactions none of which were a sham, but which had the effect of cancelling each other out.
Held: If the true nature . .
Lists of cited by and citing cases may be incomplete.
Taxes Management, Contract
Updated: 25 July 2022; Ref: scu.81036