Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
In its decision in ScottishPower (SCPL) Ltd v HMRC [2025] EWCA Civ 3 issued on 17 January 2025 the Court of Appeal considers whether companies in the ScottishPower group should be entitled to a corporation tax deduction for significant expenditure in settling a regulatory investigation. In doing so it reconsiders the well-known case of McKnight v Sheppard [1999] STC 669. In striving for simplicity the decision raises questions.
The facts stated in the sole Court of Appeal judgment (by Falk LJ) the history of the case and her key conclusions are pithily described in the case report in Tax Journal 24 January 2025. To summarise even further: Ofgem investigated how ScottishPower had dealt with certain...
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Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
In its decision in ScottishPower (SCPL) Ltd v HMRC [2025] EWCA Civ 3 issued on 17 January 2025 the Court of Appeal considers whether companies in the ScottishPower group should be entitled to a corporation tax deduction for significant expenditure in settling a regulatory investigation. In doing so it reconsiders the well-known case of McKnight v Sheppard [1999] STC 669. In striving for simplicity the decision raises questions.
The facts stated in the sole Court of Appeal judgment (by Falk LJ) the history of the case and her key conclusions are pithily described in the case report in Tax Journal 24 January 2025. To summarise even further: Ofgem investigated how ScottishPower had dealt with certain...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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