- Cited — The Commissioners For HMRC v Bluecrest Capital Management LP & Ors 2023-12-15
“…t the legislation in question did not admit of a purposive interpretation based on the Ramsay line of authorities (WT Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300), because in this context “possession” meant the immediate legal right to possession which, as a matter of real property law, became vested in the SPVs once th…”
- Applied — BCM Cayman LP & Anor v The Commissioners for HMRC 2023-10-12
“…iewed realistically, were caught by the relevant legislation, construed purposively, applying the approach in Ramsay (W T Ramsay v Inland Revenue Commissioners [1982] AC 300). The FTT had rejected HMRC’s Ramsay argument(see FTT [115]-[136]) and the UT had not considered it necessary to deal with the argument given the dismissal of …”
- Cited — Amarjit Bhaur & Ors v Equity First Trustees (Nevis) Limited & Ors 2023-05-18
“…[1982] AC 300 there has been an increasingly strong and general recognition that artificial tax avoidance is a social evil which puts an unfair burden on the shoulders of th…”
- Followed — Altrad Services Limited & Anor v The Commissioners for HMRC 2023-05-03
“…WT Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300, and the line of cases following it.…”
- Cited — London Luton Hotel BPRA Property Fund LLP v The Commissioners for HMRC 2023-04-04
“…Nicholls gave the leading judgment, and as part of a discussion of the “new approach” heralded by the Ramsay case (WT Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300), said this:…”
- Cited — Oisin Fanning v The Commissioners for HMRC 2023-03-13
“…on was a sham, or that the correct interpretive approach is one that simply disregards the Option under Ramsay principles (WT Ramsay Ltd v Inland Revenue Comrs [1982] AC 300).…”
- Cited — Oisin Fanning v The Commissioners for HMRC 2023-03-13
“… a literal interpretation of the words, but must have regard to the context and scheme of the relevant Act as a whole: see WT Ramsay Ltd v Inland Revenue Comrs [1982] AC 300, 323; Barclays Mercantile Business Finance Ltd v Mawson, para 29. The essence of this approach is to give the statutory provision a purposive construction in o…”
- Cited — Khan v Revenue & Customs (Rev 1) 2021-04-30
“…ial unity. In this regard Mr Sykes relied on the fourth of the well-known principles adumbrated by Lord Wilberforce in WT Ramsay v Inland Revenue Commissioners [1982] AC 300 at pp 323G-324D. In that passage, Lord Wilberforce said that:…”
- Cited — Eynsham Cricket Club v Revenue & Customs 2021-02-23
“…[1982] AC 300…”
- Cited — Revenue And Customs v Development Securities Plc & Ors 2020-12-15
“…Customs (“HMRC”) sought to challenge the efficacy of the exercise on the basis of the approach first introduced by WT Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300, but they did not persist with that contention. By the time, therefore, that the matter came before the FTT, it was common ground that the scheme was effective…”
- Cited — General Transport Service SPA v Revenue And Customs 2020-03-18
“…rst, it was submitted that the decision is contrary to the fundamental principle that taxes and duties can only be imposed by clear words: W.T Ramsay Ltd v IRC [1982] AC 300.…”
- Cited — Rossendale Borough Council v Hurstwood Properties (A) Ltd & Ors 2019-03-07
“…uable that the leases fall to be disregarded by the application of the principles established by the decisions in W.T.Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300 (Ramsay) and later cases?…”
- Applied — The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue And Customs 2019-02-06
“…r Tribunal (“the FTT”) (Judge J Gordon Reid QC and Mr Ian Malcolm) concluded that the approach first introduced by WT Ramsay Ltd v Inland Revenue Commissioners [1982] AC 300 applied and, hence, that CGT had not been avoided, and the Upper Tribunal (“the UT”) (Arnold J and Judge Roger Berner) agreed. The appellants, however, challen…”