Commentary

B2.438 Financial expenditure—case law

Business tax
Business tax | Commentary

B2.438 Financial expenditure—case law

Business tax | Commentary

B2.438 Financial expenditure—case law

For further commentary on the deductibility of financing expenditure, see B2.436 and B2.437.

The deductibility of interest for corporation tax purposes is governed by the loan relationships regime (see Division D1.7).

Deductible interest costs

The following have been held to be deductible:

  1.  

    •     commission paid to a guarantor in respect of a company's running indebtedness1

  2.  

    •     half-yearly payments made by one company to another to secure a commanding position in the management of the recipient company2

  3.  

    •     payments to a trust to acquire shares in the taxpayer company for the benefit of the employees and to

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