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Prudential: Main Purpose Again

Rupert Shiers McGrigors LLP provides a practical guide to the operation of the 'main purpose' test responding to comment on the Prudential case
The tax community has suffered for at least a decade from a lack of guidance on the 'main purpose' test which is now littered liberally throughout the Yellow Book. What there is has had to be read across from cases on ICTA 1988 s 703 and one case on the CFC motive test (ABTA Ltd v IRC [2003] STC (SCD) 194). HMRC has been understandably reluctant to give a clear statement on when the test applies and Counsel have struggled with a lack of data to work with. Yet at least since the introduction of a test of this sort in the loan relationships rules...

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