Anti-avoidance case law and tax: Direct taxes and stamp duties
Resource type: Practice Note
This practice note summarises the development of anti-avoidance case law from WT Ramsay v Inland Revenue Commissioners (1982) 54 TC 101 to date. It includes recent decisions of the First-tier and Upper Tribunals on the application of the Ramsay principle together with some other key avoidance cases. It also includes some practical tips for structuring transactions to reduce the risk of attack by HMRC based on anti-avoidance case law.