Commissioners of Inland Revenue v Willoughby

JurisdictionUK Non-devolved
JudgeLORD NOLAN,LORD MUSTILL,LORD HOFFMANN,LORD CLYDE,LORD HUTTON
Judgment Date10 July 1997
Judgment citation (vLex)[1997] UKHL J0710-1
Date10 July 1997
CourtHouse of Lords
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    • TRY VLEX
64 cases
  • Tower Radio Ltd and Another
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • 11 July 2013
    ...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......
  • TC03103: Philip Boyle
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • 29 November 2013
    ...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......
  • Commissioners for HM Revenue and Customs v Fisher and another
    • United Kingdom
    • Supreme Court
    • 21 November 2023
    ...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......
  • Fisher and Others
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • 14 August 2014
    ...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
  • Should Corporate Tax Avoidance Be Criminalised?
    • United Kingdom
    • Southampton Student Law Review No. 6-1, January 2016
    • 1 January 2016
    ...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......

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