The Application Of Ramsay Rule In Shiu Wing Limited & ORS V. Commissioner Of Estate Duty

Trust, from the day it was born, in order to escape the tax burden, and from the development of the Trust several hundred years of history, "evasion" has become its attributes the rapid development of important reasons. With the advance of economic globalization, offshore trusts also become a trustee of the new stage of development, the use of offshore trusts to avoid their tax avoidance has become a new means. Trust between people in a series of complex staggered Trust is designed to allow the tax department prevent. This has also enabled the Trust tax evasion and tax law interpretation of the tax law profession to become a new hotspot. This paper first discussed the concept and scope definition; Then, on this basis, Preliminary analysis of the second part of the Ramsay principle of the establishment and development; Part III position of Hong Kong landmark case -- "Long Ding Wen Trust tax evasion case" to study the carrier, Through the entire complex the trust staggered screen design, analysis Ramsay principle in the case of application; In the final analysis of the case on the basis of the principle of Ramsay summed up China's tax law to explain where we can draw on.