Coursework.Info - Inspiration in an Instant

On the left is an image preview of every page of this document, and below are the first 150 words with formatting removed:

Taxation Law Tax Avoidance: Substance over Form? In light of the MacNiven v Westmoreland 1 case, it would appear that the broad interpretation of Ramsay, favouring substance over the form of a transaction, as espoused by the Revenue, would seem to be at an end. This will be illustrated by examining the speeches of Lords Nicholls and Hoffman in particular. Although the composite transaction doctrine 2 remains, it is secondary to the court's decision as to when a fiscal concept can be construed commercially or as opposed to juristically. 3 A problem that this does seem to raise is ascertaining what concepts, in regard to their context, can be construed commercially or legalistically. This essay will first begin by briefly looking at the historical development of the Ramsay approach, as it has come to be called, and the effect it has had on people's attitudes towards tax avoidance schemes. The purpose...

Get instant access

• Instant, unlimited access to our documents in full
• Swap your work for free access, or pay £4.99
• To see the full version of this document and 146,871 others

OR

Receive email updates for this category

• Simply tell us your email address and receive a weekly Study Help Email for FREE
• Receive 3 FREE essay views with each email
• Get all the latest essays from Coursework.Info & discussion from TheStudentRoom.co.uk