Wholly and exclusively: how to establish purpose: contents
S34 Income Tax (Trading and Other Income) Act 2005, S54 Corporation Tax Act 2009
Introduction and layout of guidance
When looking to establish the ‘purpose’ of expenditure you are looking to establish the aims or objectives underlying the expenditure. Romer LJ in the case of Bentleys Stokes & Lowless v Beeson  33 TC 491 (see BIM37400) at page 503 said unequivocally:
`The sole question is whether the expenditure in question was ‘exclusively’ laid out for business purposes, that is: What was the motive or object in the mind of the two individuals responsible for the activities in question?’
This points very clearly to the need to look at the mind of the trader to establish the purpose.
The following guidance considers the meaning of wholly and exclusively, how to establish purposes and the distinction between purpose and motive.
BIM37055How to establish purpose: whose purpose
BIM37060How to establish purpose: purpose is a question of fact
BIM37065How to establish purpose: a question of fact to be decided by examining the evidence
BIM37070How to establish purpose: objective or subjective test
BIM37075How to establish purpose: distinction between purpose and motive