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LexisNexis Conference: 'Tax Avoidance in 2006', 15 May 2006, reported by Matthew Hutton, Chartered Tax Adviser
Speakers quoted:
Patrick Cannon, Barrister, 15 Old Square
Pete Miller, Director, National Tax, Ernst & Young LLP
Paul Morton, Head of Group Tax, Reed Elsevier
Martin Scammell, Partner, Ernst & Young LLP
Geoff Lloyd, Director, Central Compliance at HMRC
Timothy Lyons QC, Barrister, 15 Old Square
LexisNexis Conference: 'Tax Avoidance in 2006' 15 May 2006 reported by Matthew Hutton Chartered Tax Adviser
Speakers quoted:
Patrick Cannon Barrister 15 Old Square
Pete Miller Director National Tax Ernst & Young LLP
Paul Morton Head of Group Tax Reed Elsevier
Martin Scammell Partner Ernst & Young LLP
Geoff Lloyd Director Central Compliance at HMRC
Timothy Lyons QC Barrister 15 Old Square
Aidan O'Carroll National Head of Tax Ernst & Young LLP
'Abuse' and Ramsay
Patrick Cannon summarised the recent ECJ decision in Halifax plc v CCE [2006] STC 919 as applying the concept of 'abuse' where (a) the taxpayer obtains a tax advantage which is contrary to the purpose of the relevant legislation and (b) objective factors show that obtaining that advantage is the essential aim of the transaction. This doctrine currently applies only to Community law and...
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