How UK tax law draws the line between legitimate planning and abuse, and the statutory and judicial weapons deployed against arrangements that cross it.
A scheme that saves tax on paper can be unwound, recharged or even prosecuted, so knowing which rule bites — and when — matters more than the saving itself. This chapter opens with the spectrum running from mitigation through avoidance to evasion, including the corporate offence of failing to prevent the facilitation of tax evasion under the Criminal Finances Act 2017. It then works through the two broad counter-measures: the General Anti-Abuse Rule with its double reasonableness test, and the Ramsay principle of purposive interpretation applied to pre-ordained transactions with artificial steps. Finally it turns to the targeted regimes — the off-payroll working rules (IR35) and status determinations, the section 455 charge on close company loans to participators, and the inheritance tax rules on gifts with reservation of benefit and the pre-owned assets charge.
