Jurisdiction(s):
United Kingdom

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Key definition

Investments definition

What does Investments mean? In practice, investments are financial products or rights acquired with the expectation of income or capital growth, such as shares, bonds, fund units and derivatives. In UK financial services law, however, the regulated concept is “specified investments” under the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (SI 2001/544) (RAO). This defined list includes, among others, shares, debentures and loan stock, government and public securities, warrants, units in a collective investment scheme, options and futures, contracts for differences, and rights under a contract of insurance. Whether a firm must be authorised, may communicate financial promotions, or owes particular...

Ramsay where legislation is prescriptive: Macniven v Westmoreland and Mayes on purposive construction in UK tax law and GAAR context

Published by a LexisNexis Tax expert

Practice notes

Ramsay principle

Lexis+® UK Tax thanks Nigel Doran of Macfarlanes LLP for his input on an earlier version of this Practice Note, though the opinions stated are those of Lexis+® UK Tax. This Practice Note has since been reviewed and updated by Aparna Nathan, KC, Devereux Chambers.

Background on the Ramsay principle is set out in the Practice Note: Ramsay as a guide to statutory construction. As the courts have refined Ramsay, various strands of the principle have been identified. One such strand is that certain charging provisions employ language so technical and/or prescriptive that Ramsay does not apply, meaning it leaves untouched the tax consequences of the transactions at issue. That flows from the fundamental point that Ramsay is a matter of construing statutes: where a transaction matches the statutory description, it is taxed in line with the legislation, regardless of the taxpayer’s aim of lowering their tax liability.

Other facets of Ramsay are addressed in further Practice Notes (see: Ramsay and composite transactions, Ramsay—reality and legal form, and Ramsay in reverse)...

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Web page updated on 21/05/2026

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