In order to argue an interpretation of Tax Law, the advocate must:
1st analyse the burden of proof, i.e. what the taxpayer [‘TP’]  has to prove as a matter of law regarding the relevant tax treatment by reference to:
·       the statutory framework and provisions applicable to the dispute; and
·       case law.
2nd determine the specific questions of fact,  i.e.
·       what the TP has done to fall within the ambit of the specific tax treatment asserted; or
·       whether there is a different tax treatment, because as a matter of fact, the TP did something else.
This requires detailed investigation and the drafting of a chronology of events.
3rd consider the following ‘cannons of construction’:
·       It is ‘preferable to begin with the interpretation of the legislation, and the fundamental question whether it can be given a purposive interpretation going beyond its literal terms: that is to say, whether a Ramsay approach is possible at all, and if so, the purposive construction on which it is to be based. … The question next arises how, on its proper interpretation, the legislation is to be applied to the facts.’ (UBS AG v. Revenue and Customs Comrs [2016]).
·       Where a statute contains no explanation of the purpose of the provision on which a purposive interpretation might be based, the judge may consider the historical background to and development of the legislation by reference to budget notes, explanatory notes and case law.
·       ‘… The driving principle in the Ramsay line of cases continues to involve a general rule of statutory construction and an unblinkered approach to the analysis of the facts. The ultimate question is whether the relevant statutory provisions, construed purposively, were intended to apply to the transaction, viewed realistically.’ (Collector of Stamp Revenue v. Arrowhead Assets Ltd [2003]).
·       When interpreting a statute, a court may adopt a strained interpretation instead of one that would be contrary to the clear intention of Parliament (Luke v. Inland Revenue Commissioners [2019]). The intention of Parliament must be clearly found on the wording of the legislation (Hancock v Revenue and Customs Comrs [2019]. An inconsistency is not sufficient. There must be a clear contradiction.
·       The headings in the statute are aids to construction (Stephens v Cuckfield Rural District Council [1960]).
·       The Explanatory Notes to an Act of Parliament may also be relevant to interpreting specific statutory provisions (R (otao Westminster City Council) v. National Asylum Support Service [2002] & Christianuyi v. Revenue and Customs Comrs [2018]).
·       For reference to be made to Hansard, there needs to be an ambiguity, obscurity or absurdity in the statutory interpretation that justifies such resort (Pepper v. Hart [1992]).