Explanatory Notes

Corporation Tax Act 2009

2009 CHAPTER 4

26 March 2009

Commentary on Sections

Part 16: Companies with investment business

Overview

Chapter 2: Management expenses
Section 1220: Meaning of “unallowable purpose”

3092.This section explains “unallowable purpose”, an expression used in section 1219(2)(b). It is based on section 75 of ICTA.

3093.Subsection (1) is the basic rule that explains the ordinary meaning of “unallowable purpose”.

3094.Subsection (2) extends “unallowable purpose” to include investments held in connection with arrangements to secure a tax advantage.