The Ramsay principle, as stated in Furniss v. Dawson [1984] STC 153, allows tax legislation to applied to the substance of a transaction. Steps inserted artificially with no commercial (business) purpose other than tax avoidance may be disregarded. Whilst the steps inserted into a scheme may have some business effect, the question is not what is the effect of inserting the artificial steps but what is their purpose.

Andrew Park QC appeared for the Inland Revenue

See also Article by David Goldberg Q.C.