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Tax and the City review for July 2021

Mike Lane and Zoe Andrews (Slaughter and May) report on the recent developments, including some encouraging findings on the UK’s position as a leading centre for financial services investment.

West Burton: meaning of ‘brought into account’

West Burton Property Ltd v HMRC [2021] UKFTT 160 concerns the deductibility of deferred revenue expenditure (DRE) incurred in the course of carrying on a property business and may at first glance seem an odd choice for inclusion in this article. However it contains principles relevant to the calculation of trading profits and as Judge Beare explained if HMRC had succeeded in their submissions it would have driven a coach and horses through the tax system rendering it incapable of functioning effectively and appropriately. At the heart of this case is the interaction between the accounting rules and the tax computation rules.

WBPL owned a power station and had incurred...

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