Altrad Services Ltd v Revenue and Customs Comrs

Applying the Ramsay purposive-construction approach (as restated in Rossendale BC v Hurstwood Properties), the statutory requirement in the Capital Allowances Act 2001 that a taxpayer 'ceases to own' plant and machinery is not satisfied where assets are disposed of only briefly before being reacquired as part of a pre-planned, self-cancelling tax-avoidance scheme.