MacNiven v Westmoreland Investments Ltd

JurisdictionEngland & Wales
Date1997
Year1997
CourtChancery Division
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6 cases
  • MacNiven v Westmoreland Investments Ltd
    • United Kingdom
    • House of Lords
    • 8 February 2001
    ...strikes down devices or stratagems designed to avoid its terms or exploit its loopholes.’ The present case: the appeal to Carnwath J [1997] STC 1103 63 My Lords, after what I fear was a lengthy analysis of the Ramsay principle I return to the present appeal. Carnwath J, who allowed an appe......
  • Littlewoods Retail Ltd and Others v The Commissioners for HM Revenue & Customs
    • United Kingdom
    • Chancery Division
    • 28 March 2014
    ...(Knox J), Barnett v Brabyn (Inspector of Taxes) [1996] STC 716 at 723c-j (Lightman J), MacNiven v Westmoreland Investments Ltd [1997] STC 1103 at 1133 (Carnwath J) and King v Walden (Inspector of Taxes) [2001] STC 822 (Jacob J, discussed in more detail 176 In the Westmoreland case, the i......
  • MacNiven v Westmoreland Investments Ltd
    • United Kingdom
    • Court of Appeal (Civil Division)
    • 23 October 1998
  • Andrew Chappell v The Commissioners for HM Revenue and Customs
    • United Kingdom
    • Court of Appeal (Civil Division)
    • 4 August 2016
    ...also stressed the real-world nature of the interest obligations that were being discharged: "95. The Special Commissioners found [1997] STC 1103, 1116G that: "all the loans made to the taxpayer company from 1980 onwards were real loans and the taxpayer company used them for real purposes, v......
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