Developments
More recent cases have tended to move away from a narrow focus on disregarding circular transactions and inserted pre-ordained steps with no commercial purpose. A number of tax counsel have cited the following comments by Ribeiro P in Collector of Stamp Revenue v Arrowtown Assets Ltd HKCFA 46, para 35 with approval as an authoritative statement of the prevailing view of the judiciary on the application of legislation in tax avoidance cases:
- The driving principle in the Ramsay line of cases continues to involve a general rule of statutory construction and an unblinkered approach to the analysis of the facts. The ultimate question is whether the relevant statutory provisions, construed purposively, were intended to apply to the transaction, viewed realistically
Read more about this topic: The Ramsay Principle
Famous quotes containing the word developments:
“I don’t wanna live in a city where the only cultural advantage is that you can make a right turn on a red light.
Freedom from labor itself is not new; it once belonged among the most firmly established privileges of the few. In this instance, it seems as though scientific progress and technical developments had been only taken advantage of to achieve something about which all former ages dreamed but which none had been able to realize.”
—Hannah Arendt (1906–1975)
“The developments in the North were those loosely embraced in the term modernization and included urbanization, industrialization, and mechanization. While those changes went forward apace, the antebellum South changed comparatively little, clinging to its rural, agricultural, labor-intensive economy and its traditional folk culture.”
—C. Vann Woodward (b. 1908)