Howden Joinery Group Plc and Another v Revenue and Customs: FTTTx 13 Mar 2014

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.
[2014] UKFTT 257 (TC), [2014] STI 2015, [2014] SFTD 1186
Bailii
England and Wales

Updated: 01 June 2021; Ref: scu.525265