Comparative Perspectives on Revenue Law: Essays in Honour of by John Avery Jones, Peter Harris, David Oliver

By John Avery Jones, Peter Harris, David Oliver

Devoted to the paintings of John Tiley, the greatest tax educational within the united kingdom for greater than 20 years, this quantity of essays specializes in subject matters that, between others, encourage the writings of Tiley. the 1st of those subject matters, tax avoidance, includes utilizing tax legislations in a fashion that's opposite to legislative rationale. the second one of those subject matters, taxation of the relations, includes right id of the tax topic and is hence one of many basic structural positive aspects of source of revenue tax. Drawing on ancient precedent, educational excellence and private event, the significance of Tiley's contribution to the tax box is pointed out via contributions by way of the various world's so much influential tax writers.

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80 Although the Explanatory Notes refer to s. 81 This attempt to cast the misuse and abuse test as a rule of construction explains why the original version of sub-s. 245(4) applied ‘for greater certainty’. This phrase was deleted in 2005 with retroactive effect. 83 As a result, it may well be that the GAAR was necessary to require the courts to follow a purposive 78 79 81 82 83 For a detailed analysis, see Arnold and Wilson (1988, pp. 1164–6). 80 Canada (1988, section 245). Dodge (1988, p. 21).

36 comparative perspectives on revenue law time on or after 1 April 1996. By s 150A(1) (also inserted by the Finance Act 1996) a ‘debt contract’ is a contract under which a qualifying company (which means, with irrelevant exceptions, any company: see s 154(1)) ‘as any entitlement . . to become a party to a loan relationship’. A ‘loan relationship’ includes a government security. So the short question is whether the Citibank option gave it an entitlement to gilts. That depends upon what the statute means by ‘entitlement’.

This phrase was deleted in 2005 with retroactive effect. 83 As a result, it may well be that the GAAR was necessary to require the courts to follow a purposive 78 79 81 82 83 For a detailed analysis, see Arnold and Wilson (1988, pp. 1164–6). 80 Canada (1988, section 245). Dodge (1988, p. 21). : ‘Subsection 245(4) does not create an alternative test with regard to the definition of avoidance transaction. Instead, it indicates the proper construction of section 245 with respect to transactions that appear to be tax-motivated but that, arguably, do not produce tax results that frustrate the intention of Parliament.

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