Corporation tax -management expenses- rental guarantee payments made by holding company –lump sum release payments – rental guarantee payments and provision for future guarantee payments – ‘expenses of managing the investment business’ – duality of purpose – capital or revenue — held – lump sum release payments deductible management expenses – not capital in nature -guarantee payments and provision for future guarantee payments expenditure on assets not on investment business -non deductible – re-current payments – revenue in character.
Citations:
[2014] UKFTT 257 (TC), [2014] STI 2015, [2014] SFTD 1186
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 09 December 2022; Ref: scu.525265
