Taxation U.K.

Tax Avoidance

By Rebecca Murray
Sweet & Maxwell U.K. May 2012

Specifications

ISBN-13
9781847037749
Publisher
Sweet & Maxwell U.K.
Publication
May 2012
Format
Hardback
Jurisdiction
U.K. ? Countri(es) for reference only

Details

Tax Avoidance draws together in one source all matters concerning UK tax avoidance, including detailed discussion of all UK and EU tax avoidance legislation and case law. It covers both direct and indirect taxes.

Within this new edition you will find:

  • Updated analysis of the Ramsay principle and how it has evolved over the last three decades and the difference between the Ramsay principle and the Sham Doctrine
  • Analysis of the key avoidance provisions, including the recently introduced Transfers of Income Streams provisions and the Sales of Occupation Income and Transactions in Land rules
  • Expert discussion of the recently amended Transactions in Securities rules
  • Detailed coverage of the Transfers of Assets Abroad provisions
  • In depth discussion of the EU principle of Abuse and its application in both direct and indirect tax in the UK

Table of Contents

  1. Ramsay principle
  2. Sham
  3. The concept of trade in a tax avoidance context
  4. Transfer of Assets Abroad
  5. Transactions in land
  6. Transactions in Securities
  7. Sales of Occupation Income
  8. Transfer of Income Streams
  9. Abuse

About the Author

Rebecca Murray is a Barrister at Temple Tax Chambers specialising in direct tax
and VAT, with significant experience acting for the taxpayer and the revenue in tax
advisory and litigation matters.

Recent tax avoidance cases include HMRC v Tower Mcashback LLP 1 & Anor (Supreme Court) and Eclipse Film Partners (No 35) LLP v HMRC (FTT) in which she acted as junior counsel for the crown and Aberdeen Asset Management Plc v HMRC (UT) and Mr & Mrs Coll (FTT), for the taxpayer.

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