Recent judicial consideration of the unallowable purpose rule in CTA 2009 s 441 has shed some light on the scope of its application. In addition, the June 2013 Modernising the taxation of corporate debt and derivative contracts consultation document saw HMRC bare a little more of its soul regarding s 441. Given these developments, it is a good time to take stock on where things currently stand with the unallowable purpose rule in s 441.
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