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House of Lords tax cases

Seeded tax cases from the House of Lords in United Kingdom.

Country

United Kingdom

Court

House of Lords

Cases

7

2004

Barclays Mercantile Business Finance Ltd v Mawson (HM Inspector of Taxes)

[2004] UKHL 51

Capital allowances are available where the taxpayer incurs real expenditure on the acquisition of plant for use in its trade; the Ramsay approach is a tool of statutory construction, not a freestanding anti-avoidance doctrine that disregards genuine transactions.

2004

Inland Revenue Commissioners v. Scottish Provident Institution

[2004] UKHL 52

The Ramsay approach requires the court to consider the transaction in its commercial reality and disregard steps inserted solely to obtain a tax advantage.

1992

Pepper (Inspector of Taxes) v. Hart

[1993] AC 593

Courts may refer to Parliamentary materials (Hansard) as an aid to construction of legislation where the legislation is ambiguous and there is a clear ministerial statement.

1984

Furniss v. Dawson

[1984] AC 474

The Ramsay principle extends to preordained series of transactions into which an intermediate step is inserted with no business purpose other than tax avoidance.

1981

W.T. Ramsay Ltd v. Inland Revenue Commissioners

[1981] UKHL 1

Where a transaction consists of preordained steps inserted for the sole purpose of tax avoidance and having no commercial purpose other than tax saving, the courts may consider the transaction as a whole rather than its individual steps.

1941

Lord Howard de Walden v Inland Revenue Commissioners

[1942] 1 KB 389

Anti-avoidance legislation directed at transfers of assets abroad must be construed to give effect to its anti-avoidance purpose; a taxpayer who has used elaborate machinery to avoid tax cannot complain if the resulting charge is heavy.

1935

Inland Revenue Commissioners v. Duke of Westminster

[1936] AC 1

Every person is entitled to so arrange their affairs that the tax attaching is less than it otherwise would be, and the courts will give effect to such arrangements unless the statute otherwise provides.

Important disclaimer

This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.