Elections – Expenses. The phrase 'expenses incurred' in s 111(2) of the Political Parties, Elections and Referendums Act 2000 was most naturally understood, such that expenses might be incurred by voluntarily making a payment which diminished a person's assets, as well as by assuming an obligation or liability to make such a payment. Accordingly, the Divisional Court held that the defendant Electoral Commission had misinterpreted the definition of 'referendum expenses' and that Vote Leave's payments to an advertising firm at another's request for the agreed purpose of paying for advertising which he had ordered for referendum purposes had been referendum expenses.