In Centrica Overseas Holdings Ltd v HMRC [2020] UKFTT 197 (TC) (23 April) the First-tier Tribunal (FTT) held that expenditure incurred by an investment company in connection with a sale of the businesses of a subsidiary was not expenses of management within CTA 2009 s 1219.
COHL was an intermediate holding company in the group headed by Centrica plc. It had a Dutch subsidiary Oxxio and in 2009 Centrica made a strategic decision to sell the businesses of Oxxio and its subsidiaries preferably by way of a sale of Oxxio’s shares. In the event there was a partial sale by Oxxio in 2011 of the assets of its subsidiaries. Centrica incurred expenses of £3.8m during the period 2009 to 2011 paid to three firms for services relating to the transaction including financial advice finding a buyer vendor due diligence and advice on...
