«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.
For those who have had experience dealing with them, the mere mention of consultants will conjure the image of insipid,
economic parasites whose
sole apparent
purpose of existence is to bleed companies dry while implementing large - scale redundancies.
The cumulative conditions of Article 5 (1) exempt such acts of reproduction that are (1) temporary, (2) transient or incidental, (3) integral and essential parts of a technological process, (4) that have the
sole purpose of enabling a transmission in a network between third parties by an intermediary or a lawful use of a work or protected subject matter, and (5) that do not have any independent
economic significance (para. 61).