Keyword

ramsay principle

2 decisions turning on ramsay principle.

Explainaway Limited Quartfed Limited Parastream Limited v Commissioners for Her Majesty's Revenue and Customs

Tax LawFirst-tier Tribunal (Tax)24 Jun 2011[2011] UKFTT 414 (TC)Added 6 Aug 2026

Paul Rackham Limited ("PRL"), a UK company carrying on agriculture and property business, held shares in Waste Recycling Group plc and, advised by Deloitte & Touche, adopted a "Company Derivative Plan" to mitigate corporation tax…

EDI Services Limited EDI International Limited H & M Services Limited H & M (Uk) Limited v Her Majesty's Revenue & Customs

Tax LawSpecial Commissioners of Income Tax26 Apr 2006Added 6 Aug 2026

The four appellant companies — EDI Services Limited, EDI International Limited, H&M Services Limited and H&M (UK) Limited — were two small computer software groups, each holding company owning the other pair as subsidiaries. Mr…

trading-arrangements national-insurance moneys worth secondary-class-1-contributions payment-in-kind