The general principle in favour of a strict construction against HMRC has been modified. Parliament has introduced anti-avoidance provisions in some taxes which are phrased in broad language which deliberately eschews legal terms of art. For example, IHTA 1984, s 268, containing the provisions relating to associated operations, falls within this category. Such provisions have not always been strictly construed against HMRC. As Lord Reid said in Greenberg v IRC1:
'“We seem to have travelled a long
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