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Home / Simons-Taxes /IHT, trusts and estates /Part I2 Statutory interpretation /Division I2.2 Form and substance of transactions /Form and substance of transactions / I2.211 The Ramsay principle after Tower MCashback Llp

I2.211 The Ramsay principle after Tower MCashback Llp

IHT, trusts and estates

The Ramsay principle has undergone a significant reformulation since the turn of the century, particularly following the Supreme Court decision in HMRC v Tower MCashback

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D6.503 International movement of capital—reportable transactions and events

E5.607 Corporate members

D1.8101 Groups of companies

I3.367 Fall in value relief—changes in interests in land

E4.11120 Additional annual returns by employers—overview

I3.750 POAT—introduction to existing arrangements

E1.1502 Tax treatment of transfers with accrued interest

I5.226 Disposals of QIIPs for consideration

E8.811 National Insurance number—refusal of application

D2.250 Group relief—limited rights, variable rights and options attaching to ordinary shares

C2.1231 Leases—deemed premiums

C2.108 Contingent liabilities

D3.410 Benefits provided by close companies to participators

I5.1122 More than one settlor (income tax and CGT)

E7.234 Other types of lifetime benefit lump sum

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

B2.472 Tax and tax-related expenditure

C3.1706 PPR relief where there is job-related accommodation

D4.412 CFCs—excluded territories exemption

E6.102K Statutory residence test—the definition of a 'home'

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