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Main Purpose: Practice and Pitfalls

Rupert Shiers and Jason Collins Senior Solicitors McGrigors consider the 'main purpose' test under the new VAT disclosure rules
In The Tax Journal 23 August 2004 Issue 755 Chris Tailby on behalf of Customs considered how a trader and his adviser should have little difficulty in deciding whether particular arrangements meet the 'main purpose' test under the 'hallmark' part of the new VAT disclosure regime (see VATA 1994 Schedule 11A paragraphs 4 and 5). In doing so he cited a number of cases where advisers have sought to 'dress up' arrangements in an attempt to give them a veneer of commerciality. This article quite simply is our response. We see real areas of concern both for Customs and for taxpayers; we aim...
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