«1) If when determining the
liability of a person to taxation, duty or similar charge due under
statute in the UK it shall be
established that a step or steps have been included in a transaction giving rise to that
liability or to any claim for an allowance, deduction or relief, with such steps having been included for the sole or one of the main purposes of securing a reduction in that
liability to taxation, duty or similar charge with no other material economic purpose for the inclusion of such a step being capable of demonstration by the taxpayer, then subject to the sole exception that the step or steps in question are specifically permitted under the term of any legislation promoted for the specific purpose of permitting such use, such step or steps shall be ignored when calculating the resulting
liability to taxation, duty or similar charge.
«A defendant's conduct can not be deemed «unreasonable» when that conduct has been expressly sanctioned by
statute, for it is well
established that, even where «it would be a nuisance at common law, conduct that is fully authorized by statue, ordinance or administrative regulation does not subject the actor to tort
liability.