CFM38100 - Loan relationships: tax avoidance: unallowable purpose: contents

  1. CFM38110
    Overview
  2. CFM38115
    Technical summary
  3. CFM38120
    Is there an unallowable purpose?
  4. CFM38125
    Whose purpose?
  5. CFM38130
    A main tax avoidance purpose: summary and background
  6. CFM38135
    A main tax avoidance purpose: determining purposes and main purposes
  7. CFM38140
    The meaning of tax advantage
  8. CFM38145
    Purposes of activities not within the charge to Corporation Tax: Rule and background
  9. CFM38150
    Attributable on a just and reasonable apportionment
  10. CFM38155
    Debits and exchange gains credits in relation to a loan relationship
  11. CFM38160
    Burden of proof
  12. CFM38165
    Interaction with other regimes
  13. CFM38167
    Leading case law
  14. CFM38170
    Factors relevant to assessing evidence of a main tax avoidance purpose
  15. CFM38175
    Application: general
  16. CFM38180
    Application: Hansard report
  17. CFM38190
    Situations where the unallowable purpose rule would or would not normally apply
  18. CFM38200
    Approach to enquiries