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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...
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