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Main purpose, or one of the main purposes

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The phrase ‘main purpose or one of the main purposes’ is widely used in UK tax law. A person may have more than one main purpose in entering into a transaction, and ‘a main purpose’ is a wider test than ‘the main purpose’. Cases including Snell, Lloyds TSB Equipment Leasing (No. 1) Ltd and Travel Document Service & Ladbroke Group International confirm that a transaction can have more than one main purpose and obtaining a tax advantage can be a main object of a transaction; however, in order for a purpose to be ‘main’ it must have a connotation of importance.

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