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Centre for Commercial Law Studies

Statutory Interpretation Following the Tax Law Rewrite

When: Tuesday, February 21, 2023, 3:00 PM - 5:00 PM
Where: CCLS, Room 3.1, Queen Mary, University of London, 69 Lincoln's Inn Fields London WC2A


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Between 2001 and 2010, the entire income tax and corporation tax codes were rewritten in a series of Acts, starting with the Capital Allowances Act 2001 and ending with the Taxation (International and Other Provisions) Act 2010. They adopted a special Parliamentary procedure but were not, as such, consolidation Acts. They were not intended to change the underlying law but only to make minor changes within the remit of the Tax Law Rewrite Project and the Parliamentary process for the Rewrite Acts.

In this respect, the UK income and corporation tax codes a continuous process of development from Sir Robert Peel’s Income Tax Act of 1842, the origins of which lay in Addington’s Act of 1803. Malcolm Gammie will reflect on the extent to which Courts are now prepared to draw upon the history of the relevant provisions and previous precedent when called upon to interpret the ‘simplified language’ of the rewritten Acts.

Malcolm Gammie is a barrister at One Essex Court. He is among the leading advocates at the Revenue Bar and is noted as a leading practitioner in the commercial, European and international taxation fields. He has represented both HMRC and taxpayers in a series of high profile disputes, including most recently for HMRC the Eclipse 35 and Ingenious film scheme litigation. In the 2018 UK Chambers Bar Awards Malcolm won Tax Silk of the Year.

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