I suppose, but most of the times loopholes aren't like that.

Either they are intentional things that have unintended consequences or they are unintentional things that people didn't realize what they meant.

Sometimes they are just laws that are working as intended but somebody doesn't like them so they are labelled as a loophole.

I think there are very few loopholes that people intended to create by intentionally phrasing it weirdly.