TaxGuided
House of Lords cases

Case detail

Furniss v. Dawson

[1984] AC 474

Court

House of Lords

Date

1984-02-09

Outcome

for-government

Holding

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

Facts

Dawson interposed a Manx company in the sale of shares to a UK company solely to defer chargeable-gains tax through the rollover relief.

Reasoning

Lord Brightman extended Ramsay to circular and linear preordained schemes with non-commercial intermediate steps. The decision has been further refined by the BMBF and similar later cases.

Case metadata

Jurisdiction: United Kingdom
Topics: tax avoidance, Ramsay principle, preordained transactions
Statutes applied: Finance Act 1965

Official opinion

Open official decision

Cases cited

W.T. Ramsay Ltd v. Inland Revenue Commissioners

[1981] UKHL 1

Inland Revenue Commissioners v. Duke of Westminster

[1936] AC 1

Later cases in this library

Inland Revenue Commissioners v. Scottish Provident Institution

[2004] UKHL 52

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