'Particles' in A Gas Chamber
Lord Wilberforce described the transactions in the Ramsay and Rawling cases with this colourful (if not necessarily scientifically accurate) simile:
- In each case two assets appear, like "particles" in a gas chamber with opposite charges, one of which is used to create the loss, the other of which gives rise to an equivalent gain that prevents the taxpayer from supporting any real loss and whose gain is intended not to be taxable. Like the particles, these assets have a very short life. Having served their purpose they cancel each other out and disappear. At the end of the series of operations, the taxpayer's financial position is precisely as it was at the beginning, except that he has paid a fee, and certain expenses, to the promoter of the scheme.
Read more about this topic: The Ramsay Principle
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