Ramsay (W T) Ltd v Commissioners of Inland Revenue
| Jurisdiction | UK Non-devolved |
| Judge | Lord Wilberforce,Lord Fraser of Tullybelton,Lord Russell of Killowen,Lord Roskill,Lord Bridge of Harwich |
| Judgment Date | 12 March 1981 |
| Neutral Citation | [1981] UKHL 1 |
| Court | House of Lords |
| Date | 12 March 1981 |
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710 cases
- MacNiven v Westmoreland Investments Ltd
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Piggott (Inspector of Taxes) v Staines Investments Ltd
...Ors ELRTAX[1984] AC 474; [1984] BTC 71 IR Commrs v Burmah Oil Co Ltd TAXTAX(1981) 54 TC 200; [1982] BTC 56 Ramsay (WT) Ltd v IR Commrs ELR[1982] AC 300 Corporation tax - Surplus ACT - Acquisition by holding company - Transfer of existing subsidiary to acquired company - Dividend paid by exi......
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Fitzwilliam (Countess) and Others v Commissioners of Inland Revenue
...Burmah Oil Co Ltd TAXTAX(1981) 54 TC 200; [1982] BTC 56 Montagu's Settlement Trusts, Re ELR[1987] 1 Ch 264 Ramsay (WT) Ltd v IR Commrs ELR[1982] AC 300 Capital transfer tax - Settled property - Steps taken to mitigate tax - Whether Ramsay principle applied - Whether any combination of steps......
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Fitzwilliam (Countess) and Others v Commissioners of Inland Revenue
...v IR CommrsELR [1964] AC 612 Montagu's Settlement Trusts, ReELR [1987] 1 Ch 264 Ramsay (WT) Ltd v IR CommrsWLRELR [1979] 1 WLR 974; [1982] AC 300 Shepherd (HMIT) v Lyntress Ltd; News International plc v Shepherd (HMIT) TAX[1989] BTC 346 Snook v London & West Riding Investments LtdELR [1967]......
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5 firm's commentaries
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Weekly Tax Update - Monday 4 November 2013
...employee. The directors' purpose was that of compliance with the objective of the scheme. On the Ramsay principle (W T Ramsay Ltd v IRC [1982] AC 300), the transfer to the employee of shares in the company was a payment within the meaning of section 203(1) of the 1988 Act (cf Garforth v New......
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Business Rates Mitigation Schemes The Court Of Appeal Refuses To 'Pierce The Corporate Veil'
...this will be extremely rare. The principle in Ramsay In the case of WT Ramsay Ltd and others v. Inland Revenue Commissioners and others [1982] A.C. 300, the House of Lords (as it then was) held that, where a could be interpreted under the relevant legislation (i.e. giving rise to payment of......
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Business rates mitigation schemes – The Court of Appeal refuses to
...this will be extremely rare. The principle in Ramsay In the case of WT Ramsay Ltd and others v. Inland Revenue Commissioners and others [1982] A.C. 300, the House of Lords (as it then was) held that, where a could be interpreted under the relevant legislation (i.e. giving rise to payment of......
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Weekly Tax Update - Monday 20 May 2013
...relief should be refused on grounds of public policy. Since the seminal decision of the House of Lords in WT Ramsay Ltd v IRC [1982] AC 300 there has been an increasingly strong and general recognition that artificial tax avoidance is a social evil which puts an unfair burden on the shoulde......
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26 books & journal articles
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Consequences of a Building or other Land Being Included in the List of Assets of Community Value
...the rights of a party whom he deceived. 90 The first part of this dictum was approved by the House of Lords in WT Ramsay Ltd v IRC [1981] 1 All ER 865 at 881 per Lord Fraser. More recently, the Court of Appeal has also followed the approach in Snook , upholding a decision of the Special Com......
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Table of Cases
...79, CA 133 Rainbow Estates Ltd v Tokenhold Ltd [1999] Ch 64, [1998] 3 WLR 980, [1998] 2 All ER 860, ChD 93, 199 Ramsay (WT) Ltd v IRC [1981] UKHL 1, [1982] AC 300, [1981] 1 All ER 865, [1981] STC 174, HL 237 Ramsden v Dyson and Thornton (1866) LR 1 HL 129, 12 Jur NS 506, 14 WR 926 64 Rance ......
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Table of Cases
...Council [2015] UKFTT CR/2015/0002 (GRC) 4.58, 4.59, 4.60, 4.62, 4.67, 4.68, 4.73, 4.105, 4.116, 4.125–4.127, App 3 WT Ramsay Ltd v IRC [1982] AC 300, [1981] 2 WLR 449, [1981] 1 All ER 865, [1981] STC 174, HL 5.47 Wellington Pub Company v Royal Borough of Kensington and Chelsea [2015] UKFTT ......
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Regina v Charlton, Cunningham, Kitchen and Wheeler. Court of Appeal, Criminal Division [1995]
...of Inland Revenue and Another (ex parte Rossminster Ltd and Others) [1980] STC 42 — W T Ramsay Ltd v Commissioners of Inland Revenue [1981] STC 174 — Furniss v Dawson [1984] STC 153 — The introduction of the Spend to Save initiative by the Conservative Government in the November 1996 Budget......
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