1130. Construction of stamp duty provisions.

Most of the statutory provisions concerning stamp duty which have been enacted since the Stamp Act 1891 are to be construed as one with that Act1.

The principles applicable to the interpretation of statutes and, in particular, of tax legislation would seem to apply equally to stamp duty legislation. Although some of the propositions set out below have been said to be of particular relevance in this context, many of them come from relatively old cases and must, therefore, be considered in the light of modern trends in statutory interpretation2 and in particular the Ramsay principle3.

It has been said that