A History of the Anti-Avoidance Legislation Applying to Settlements for Income Tax Purposes

The main purpose of this study is to examine the growth and spread of income tax avoidance through the use of settlements and to analyse the background to the introduction of appropriate anti-avoidance legislation. Though there is much material available to explain the meaning of this legislation there is little to explain why it was introduced, what it was aimed at and why it took the form it did. This research fills that gap and in the process throws light on the nature of the relationships between the Inland Revenue, Parliamentary Counsel, the Chancellor of the Exchequer and Parliament. It also shows the influences each have in the policy-making and legislative processes. Although the focus is on settlements, some of the observations apply to avoidance generally and explain the development of the Revenue's attitude to it