- Cited — BCM Cayman LP & Anor v The Commissioners for HMRC 2023-10-12
“…The Court was referred to UBS AG v Revenue and Customs Commissioners [2016] UKSC 13, [2016] 1 WLR 1005, and in particular to paragraphs [61]-[67] of Lord Reed’s speech. At [68] he said:…”
- Applied — Thomas William Good v The Commissioners of HM Revenue And Customs 2023-02-10
“…Ramsay approach to statutory interpretation applies in this case. That approach was examined by the Supreme Court in UBS AG v Revenue and Customs Commissioners [2016] UKSC 13; [2016] 1 WLR 1005 at [61]-[68]. It is necessary to “have regard to the purpose of a particular provision and interpret its language, so far as possible, in th…”
- Followed — John Charman v The Commissioners for HMRC 2021-12-03
“…Further explanation of the background to Part 7 was provided by Lord Reed in UBS AG vRevenue and Customs Commissioners[2016] UKSC 13, [2016] 1 WLR 1005 as follows:…”
- Applied — Haworth, R (On the Application Of) v Revenue And Customs 2019-05-01
“…ere was a 51% chance of a high-level principle found in a decided case (say, the Ramsay approach applied recently in UBS AG v Revenue and Customs Commissioners [2016] UKSC 13, [2016] 1 WLR 1005) being held to apply in a quite different factual situation. On this basis, it would theoretically be possible for HMRC to use follower noti…”
- Cited — Rossendale Borough Council v Hurstwood Properties (A) Ltd & Ors 2019-03-07
“…ent of essentially the same principles by Lord Reed JSC (with whom the other members of the Supreme Court agreed) in UBS AG v Revenue and Customs Commissioners [2016] UKSC 13, [2016] 1 WLR 1005. The section of Lord Reed’s judgment dealing with the Ramsay approach runs from [61] to [68]. After referring to Lord Nicholls’ formulation …”
- Cited — The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue And Customs 2019-02-06
“…In UBS AG v Revenue and Customs Commissioners [2016] UKSC 13, [2016] 1 WLR 1005, Lord Reed, whose judgment included extensive reference to Lord Nicholls’ speech in the Barclays Mercantile case, said of Ramsay (at paragra…”
- Cited — City Shoes (Wholesale) Ltd & Ors v The Commissioners for HMRC 2018-03-02
“…slation have given rise to leading cases such as MacDonald v Dextra Accessories Ltd [2005] UKHL 47, [2005] STC 1111, UBS AG v Revenue and Customs Commissioners [2016] UKSC 13, [2016] 1 WLR 1005, and RFC 2012 plc v Advocate General for Scotland [2017] UKSC 45, [2017] 1 WLR 2767. But by no means all of the schemes have been litigated,…”
- Cited — Trigg v HM Revenue & Customs 2018-01-18
“…As an example of the purposive approach to statutory construction, Mr Gammie relies on the decision of the Supreme Court in UBS AG v HMRC [2016] UKSC 13 where the question was whether UBS could take advantage of a special regime under Part 7 of the Income Tax (Earnings and Pensions) Act 2003 (the “2003 Act”) fo…”