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Furniss v Dawson
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Furniss v Dawson [1983] UKHL 4 is an important House of Lords case in the field of UK tax that extended the applicability of The Ramsay Principle.[1] This came from W. T. Ramsay Ltd. v. Inland Revenue Commissioners [1982] AC 300 where a company had made a substantial capital gain and entered into a complex and self-cancelling series of transactions that generated an artificial capital loss. The House of Lords held that where a transaction has pre-arranged artificial steps which serve no commercial purpose other than to save tax, then the proper approach is to tax the effect of the transaction as a whole.
Quick Facts Furniss v. Dawson, Court ...
Furniss v. Dawson | |
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Court | House of Lords |
Full case name | Furniss (Inspector of Taxes) v. Dawson D.E.R., Furniss (Inspector of Taxes) v. Dawson G.E., Murdoch (Inspector of Taxes) v. Dawson R.S. |
Citations | [1983] UKHL 4, [1984] 1 All ER 530, [1984] AC 474, [1984] STC 153, [1984] 2 W.L.R. 226 |
Court membership | |
Judges sitting | Lord Fraser of Tullybelton, Lord Scarman, Lord Roskill, Lord Bridge of Harwich and Lord Brightman |
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