In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) examine recent case law and draft legislation, and they look ahead to how financial services will be taxed under the Labour government.
Centrica: deductibility of deal fees
The Supreme Court in Centrica Overseas Holdings Ltd v HMRC[2024] UKSC 25 concluded that the professional advisory fees incurred by Centrica in connection with the sale of a loss-making business (Oxxio) constituted capital rather than revenue expenditure and were not deductible by virtue of CTA 2009 s 1219(3)(a).
Two tests
In order for the professional fees to be deductible under s 1219 two tests had to be satisfied. The first is that the expenses are expenses of management. In the First-tier Tribunal (FTT) and Upper Tribunal (UT) HMRC had argued that the expenses were not expenses of management but by the time of the Supreme Court hearing...
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In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) examine recent case law and draft legislation, and they look ahead to how financial services will be taxed under the Labour government.
Centrica: deductibility of deal fees
The Supreme Court in Centrica Overseas Holdings Ltd v HMRC[2024] UKSC 25 concluded that the professional advisory fees incurred by Centrica in connection with the sale of a loss-making business (Oxxio) constituted capital rather than revenue expenditure and were not deductible by virtue of CTA 2009 s 1219(3)(a).
Two tests
In order for the professional fees to be deductible under s 1219 two tests had to be satisfied. The first is that the expenses are expenses of management. In the First-tier Tribunal (FTT) and Upper Tribunal (UT) HMRC had argued that the expenses were not expenses of management but by the time of the Supreme Court hearing...
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:
