Main purpose, or one of the main purposes

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...