Q&As

Should I consider whether Ramsay applies to my transaction?

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Published on LexisPSL on 23/06/2020

The following Tax Q&A provides comprehensive and up to date legal information covering:

  • Should I consider whether Ramsay applies to my transaction?

The Ramsay principle is an approach to statutory interpretation that has been developed by the courts in cases involving tax avoidance. For a general introduction to the subject, see: Ramsay as a guide to statutory construction.

Identifying whether Ramsay is likely to apply to a particular transaction will always be a matter of judgment, as there is no simple test.

Flags that could indicate that you should be thinking about Ramsay include:

  1. the underlying transaction is commercial, but extra transactions have been added on that do not have a commercial purpose

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