is very similar to the requirement that all business expenses must be "Wholly & Exclusively for the purposes of the trade".
I quite agree. I think the Revenue do themselves an appauling disservice by not exercising some common sense and fairness. These areas are not black and white. They should be capable of distinguishing between a legitimate business using an aircraft, say, for business and one which is a scam. There does appear to be an element of the Inquisition in all this, with some Inspectors being quite resentful of someone who has the funds to run an aircraft, is skillful enough to fly it themselves and is clearly making a success of their lives.