The line of cases that began with WT Ramsay Ltd v IR Commrs (1981) 54 TC 101 and continued notably through Furniss v Dawson [1984] BTC 71 to Barclays Mercantile Business Finance Ltd v Mawson [2004] BTC 414 and beyond is variously known as ‘the Ramsay principle’, ‘the Furniss v Dawson approach’, ‘purposive interpretation’ and once as ‘the new approach’, although given that Ramsay was heard by the House of Lords 40 years ago (unbelievably), the latter term is hardly now appropriate.

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