This month’s round-up, by Mike Lane and Zoe Andrews (Slaughter and May).
Centrica: deductibility of investment management expenses
In HMRC v Centrica Overseas Holdings Ltd [2022] EWCA Civ 1520 the Court of Appeal considered to what extent expenses associated with the disposal of a loss-making investment are deductible as investment management expenses under CTA 2009 s 1219.
COHL an intermediate holding company in the Centrica group wholly owned an unsuccessful Dutch investment ‘Oxxio’. Following Centrica plc’s decision in principle mid-2009 that Oxxio should be disposed of it was accounted for in the 2009 accounts as a ‘discontinued operation’ and ‘held for sale’ from 30 June 2009 as it was anticipated it would be sold by 30 June 2010. Problems with the Oxxio business meant the sale process took longer than expected. In between July 2009 and early 2011 COHL incurred certain bank ...
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This month’s round-up, by Mike Lane and Zoe Andrews (Slaughter and May).
Centrica: deductibility of investment management expenses
In HMRC v Centrica Overseas Holdings Ltd [2022] EWCA Civ 1520 the Court of Appeal considered to what extent expenses associated with the disposal of a loss-making investment are deductible as investment management expenses under CTA 2009 s 1219.
COHL an intermediate holding company in the Centrica group wholly owned an unsuccessful Dutch investment ‘Oxxio’. Following Centrica plc’s decision in principle mid-2009 that Oxxio should be disposed of it was accounted for in the 2009 accounts as a ‘discontinued operation’ and ‘held for sale’ from 30 June 2009 as it was anticipated it would be sold by 30 June 2010. Problems with the Oxxio business meant the sale process took longer than expected. In between July 2009 and early 2011 COHL incurred certain bank ...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
