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Holistic Construction

Holistic Construction

Different approaches in recent direct and indirect tax judgments.


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In the world of direct tax, the familiar Ramsay approach to interpretation has been applied to tax a disposal of shares by trustees as a single overarching transaction despite being split into stages. Meanwhile, in a VAT context, a sale and leaseback has been treated as separate transactions, so as to allow a clawback of VAT. Despite apparently jarring, both approaches are justified (and indeed necessary) in the contexts in which they arise, owing to the nature of the taxes to which the relevant decisions relate.

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* First published in Tax Journal on 5 April 2019. Reproduced with permission.

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