I2.203 WT Ramsay Ltd

I2.203 WT Ramsay Ltd

Even before the Ramsay case there were hints that the court would not apply the Westminster principle slavishly. Thus in the 1979 case of IRC v Plummer1 Lord Wilberforce said that mutually interdependent steps in a scheme could be looked at together.

'The plan now involved was explained by the brokers in great detail and its intended accomplishment set out, with timetables, in almost military precision. This … entitles and requires us to look at the plan as a whole. It does not entitle us to disregard the legal form and nature of the transactions carried out.'

In the 1981 case

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