Lloyds Bank Leasing: the ‘main objects’ test

The case of Lloyds Bank Leasing (No. 1) Ltd v HMRC [2015] UKFTT 401 (reported in Tax Journal 4 September 2015) is interesting for two key reasons. First it gives a detailed analysis of what is meant by ‘a main object’. This is a phrase which occurs in various targeted anti-avoidance provisions and so is likely to be referred to in many current and future disputes with HMRC. Second the case is remarkable for the journey it has taken through the courts so far – and the journey may well not yet be over.