Jackie Wheaton (Moore Stephens) examines the widely-used phrase in UK tax law, particularly in relation to anti-avoidance sections.
The phrase ‘main purpose or one of the main purposes’ is widely used in UK tax law particularly in the anti-avoidance sections.
For example the HMRC’s Business Income Manual at BIM60560 refers to the conditions in CTA 2010 s 356OB relating to the corporation tax treatment of certain profits and gains realised from disposals concerned with land in the UK. The provisions apply generally if a person acquiring holding or developing land realises a profit or gain from a disposal of any land in the UK and any of four conditions is met in relation to the land. Three of these conditions contain a test of whether the ‘main purpose or one of the main purposes’ for acquiring or developing the land or the property deriving its value...
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Jackie Wheaton (Moore Stephens) examines the widely-used phrase in UK tax law, particularly in relation to anti-avoidance sections.
The phrase ‘main purpose or one of the main purposes’ is widely used in UK tax law particularly in the anti-avoidance sections.
For example the HMRC’s Business Income Manual at BIM60560 refers to the conditions in CTA 2010 s 356OB relating to the corporation tax treatment of certain profits and gains realised from disposals concerned with land in the UK. The provisions apply generally if a person acquiring holding or developing land realises a profit or gain from a disposal of any land in the UK and any of four conditions is met in relation to the land. Three of these conditions contain a test of whether the ‘main purpose or one of the main purposes’ for acquiring or developing the land or the property deriving its value...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
