purpose
n. (in tax law) Recent statutes enacted to counter tax avoidance focus on the “purpose” of the taxpayer. Thus, for example, the changes effected by the Finance Act 2016 s 33 to the Income Tax Act 2007 s 684 impose a tax charge on income tax avoided when “the main purpose … of the transaction in securities … is to obtain an income tax advantage”. This replaces the approach in the previous legislation, which excluded the additional tax charge when there were “genuine commercial reasons” (previously called “bona fide commercial reasons”) for the transaction.

Similarly, “tax arrangements” are defined in the 2013 General Anti-Abuse Rule as those where “the obtaining of a tax advantage was the main purpose”.

Where a loan is for an “unallowable purpose”, interest paid on the loan is not deducted in computing the corporation tax payable (Corporation Tax Act 2009 s 441). The meaning of “purpose” (as well as “tax arrangements”) in relation to that provision is thoroughly explored in Oxford Instruments v Commrs R & C [2019] UKFTT 254 (TC). The case is authority for the proposition that the “purpose” of a company is the purpose of its directors, not the purpose of the professional advisers who devised a scheme to give a tax advantage that would enable the directors to achieve their purpose.

• guarantee payment
• guard dog
• guardian
• guardian ad litem
• guillotine
• guilty
• guilty knowledge
• guilty mind
• gunboat diplomacy
• gypsy
• habeas corpus
• habendum
• habitual residence
• hacking
• Hague Convention on International Adoption 1993
• Hague Convention on the Civil Aspects of International Child Abduction
• Hague Conventions
• Hague Rules
• half a year
• half blood
• half-secret trust
• Hamburg Rules
• handguns
• handling stolen goods
• Hansard