“The UK case law has failed to provide coherent guidance for dealing with tax avoidance. The House of Lords has admitted that all attempts at clarification have only raised fresh doubts and further appeals…Under the guise of purposive statutory interpretation the courts are making distinctions based not on the wording of the statute in context, but on external, policy considerations. The judicial approach requires a proper framework, which could be provided by layered legislation, including a principle-based GAAR.” [Judith Freedman, ‘Interpreting Tax Statutes: Tax Avoidance and the Intention of Parliament’ (2007) LQR 53, 90] Discuss.