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The vexed and litigious question of “unallowable purpose”

19 March 2024 / Author(s): David Milne KC
Issue: December 2022 / Categories: Feature

In this article, David Milne KC considers the recent decisions in “unallowable purpose” cases, many of which have arisen in loan relationships, and explains why mere knowledge of the tax advantage by the directors of the taxpayer company should not of itself deny the tax relief.

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