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David Milne KC

Barrister
David Milne KC is a barrister practising from Pump Court Tax Chambers. Email: dmilne@pumptax.com

Articles by author

The vexed and litigious question of “unallowable purpose”

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.

1 DEC 2022