Commentary

D7.310 Deductibility of expenses—decided cases

Corporate tax
Corporate tax | Commentary

D7.310 Deductibility of expenses—decided cases

Corporate tax | Commentary

D7.310 Deductibility of expenses—decided cases

In Capital and National Trust Ltd v Golder1, it was held that sums disbursed by an investment company for brokerage and stamp duty in changing its investments were not management expenses within what is now CTA 2009, s 1219. The following are further items which have not been allowed as management expenses:

  1.  

    (a)     loss on exchange on providing currency to meet the interest on the bonds of the company making the claim2

  2.  

    (b)     cost of issuing new debentures to replace existing charges3

  3.  

    (c)     part of the fees of a property holding company's surveyor and assistant surveyor4

  4.  

    (d)     cost of advertising for tenants by a property holding company5

  5.  

    (e)     part of the fees of an investment company's directors found as a fact not to have been disbursed as management expenses6

  6.  

    (f)     payments made

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