BIM37050 - Wholly & exclusively: how to establish purpose
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 [1952] 33TC491 (see BIM37400) at page 503 says 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.
| BIM37055 | Whose purpose? |
| BIM37060 | Purpose is a question of fact |
| BIM37065 | A question of fact to be decided by examining the evidence |
| BIM37070 | Objective or subjective test |
| BIM37075 | Distinction between ‘purpose’ and ‘motive’ |
