Market leading insight for tax experts
View online issue

Euromoney and the main purpose test: is the case law consistent?

Speed read
In Euromoney, the FTT held that the share for share exchange provisions of TCGA 1992 s 135 applied to the transaction in question. They were not disabled by the main purpose test in TCGA 1992 s 137, even though the avoidance of a tax liability was one of the taxpayer’s purposes. In contrast to the approach taken in Snell, the FTT thought it appropriate to consider everything that forms part of the arrangements in a wider commercial sense, not only the tax-motivated steps.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.