Commissioners of Inland Revenue v Willoughby
Jurisdiction | UK Non-devolved |
Judge | LORD NOLAN,LORD MUSTILL,LORD HOFFMANN,LORD CLYDE,LORD HUTTON |
Judgment Date | 10 July 1997 |
Judgment citation (vLex) | [1997] UKHL J0710-1 |
Date | 10 July 1997 |
Court | House of Lords |
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64 cases
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Tower Radio Ltd and Another
...wish to split a freehold estate, no express reliance on a specific statutory provision of the kind in issue in IR Commrs v WilloughbyTAX[1997] BTC 393. What there was was a decision to pay and the actual receipt of cash bonuses with an artificial scheme created in the middle whereby the mon......
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TC03103: Philip Boyle
...abroad" (see Income and Corporation Taxes Act 1988 section 743s743(5)). The Tribunal was referred to the case IR Commrs v WilloughbyTAX[1997] BTC 393 (p. 395) where the Special Commissioners rejected the argument that it was an essential requirement for the application of Income and Corpora......
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Commissioners for HM Revenue and Customs v Fisher and another
...meaning of the words. That is how Lord Wilberforce's decision was interpreted by Lord Nolan in Inland Revenue Comrs v Willoughby [1997] 1 WLR 1071, 1074. Lord Nolan said that it has now been made clear by the decision in Vestey that the charging provision of what by then had become section......
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Fisher and Others
...with premises and employees. Referring to the dictum in IR Commrs v Brebner (1963-1967) 43 TC 705, confirmed by IR Commrs v WilloughbyTAX[1997] BTC 393 (taking a lower tax route did not necessarily result in a tax avoidance motive) the real economic consequences of not being subject to bett......
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1 books & journal articles
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Should Corporate Tax Avoidance Be Criminalised?
...Murphy and Christian Chavagneux, Tax Havens: How Globalization Really Works (Cornell University Press 2010) 10. 20IRC v Willoughby [1997] 1 WLR 1071 (HL). 21ibid. 22Ramsay (WT) v IRC [1982] AC 300 (HL). 23IRC v Willoughby [1997] 1 WLR 1071 (HL). 24[1997] 1 WLR 1071 (HL),1076. 93! S.S.L.R Sh......