Ian Dixon v Revenue and Customs: SCIT 30 Mar 2006

SCIT INCOME TAX: ALLOWABLE EXPENDITURE Sch D: interest payments on a commercial mortgage- was the purpose of the mortgage to purchase just business assets or to purchase a private dwelling house as well – a question of fact – the purpose of the mortgage was to buy a parcel of assets with a mixed business and private use – the interest payments apportioned to reflect the mixed use – the appropriate rate of apportionment 35/65 private and business use based on the finding that the mortgage was to facilitate the purchase of the entire business assets plus the dwelling rather than the purchase of two properties – decision in principle to allow the Appeal in part but only in so far as substituting 35 per cent for the 50 per cent add back in respect of the interest – parties directed to agree computations in order to make final determination. Final Determination.


[2006] UKSPC SPC00531



Income Tax

Updated: 05 July 2022; Ref: scu.240289