Revenue eBrief No. 029/20

04 February 2020

"Main purpose" tests

Many sections of the taxing statutes include a “main purpose test”, particularly in the anti-avoidance sections. Revenue Tax & Duty Manual Part 33-01-01 summarises case law in the area.  The manual has been updated to include a reference to the EU mandatory disclosure regime, which comes into operation on 1 July 2020 and includes a “main benefit test”. 

The new regime includes a “lookback” reporting requirement, which will apply to reportable cross-border arrangements, the first step of which was implemented between 25 June 2018 and 30 June 2020. 

A Revenue Tax and Duty Manual setting out guidance on the practical operation of the regime will be issued in due course.