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Gripple and the purposive approach

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Gripple Ltd v HMRC considered the application of the rule in Barclays Mercantile v Mawson to a case that involved no element of tax avoidance. In the writer’s view, Parliament would clearly have intended this company to qualify for R&D relief, but the claim failed on a strict reading of FA 2000 Sch 20. The Judge was not willing to interpret the legislation ‘generously’ to allow the relief and his judgment made it clear that a ‘detailed and prescriptive’ tax code does not lend itself to a purposive approach. Will this come back to haunt HMRC in avoidance cases?

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