In WT Ramsay Ltd v IR Commrs [1982] AC 300 it was held by the House of Lords that the courts must look behind the individual steps of Ò transaction to ascertain the legal nature of the series of transactions as a whole. This was interpreted by Lord Diplock in IR Commrs v Burmah Oil Co Ltd [1982] BTC 56 (at p. 58) as meaning that the courts were entitled to disregard steps in a transaction (whether or not achieving a legitimate commercial end) inserted for no commercial purpose other than avoidance of tax liability.

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