CTM08300 - Corporation Tax: management expenses: raising finance
A company with investment businessâ€� expenses on obtaining business finance, raising capital whether in terms of loans, shares or other products are not expenses of management within Section 1219. »Ê¹ÚÌåÓýapp same will apply to interest paid.
»Ê¹ÚÌåÓýapp authority for this treatment is variously in:
- London County Freehold and Leasehold Properties Ltd v Sweet 24TC412
- Hoechst Finance Ltd v Gumbrell 56TC594 and
- Bennett v Underground Electric Railway of LondonLtd 8TC475.
However some relief may be provided under the loan relationships legislation in CTA09, Part5. For details of the loan relationships legislation see the Corporate Finance Manual (CFM3000).