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West Burton Property Ltd v Revenue and Customs (Corporation Tax – Deferred Revenue Expenditure): FTTTx 18 May 2021

Deferred revenue expenditure had been incurred in the course of carrying on a property business and formed part of the cost of the property in the Appellant’s accounts – on the sale of the property, the difference between the sale proceeds and the cost of the asset (in this case, nil because the two amounts were the same) was required by generally-accepted accounting practice to be accounted for in the Appellant’s profit and loss account – did that accounting treatment mean that the deferred revenue expenditure had not been brought into account as a debit in calculating the Appellant’s accounting profits in the financial year in which the sale occurred? – no – even if the deferred revenue expenditure had been so brought into account, should relief for the deferred revenue expenditure be denied on the basis that the sale did not take place in the course of the property business because it gave rise solely to a capital receipt? – no – appeal allowed in principle
[2021] UKFTT 160 (TC)
Bailii
England and Wales

Updated: 19 October 2021; Ref: scu.663739 br>

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