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Corporation tax – Computation of profits. The taxpayer sought to deduct payments made to a rugby club from computation of its profits for corporation tax purposes. The First-tier Tribunal (Tax Chamber) and the Upper Tribunal (Tax and Chancery Chamber) upheld the decision of Revenue and Customs Commissioners to disallow the deductions and found that the payments were not 'wholly and exclusively laid out or expended for the purposes of the trade', pursuant to s 74(1) of the Income and Corporation Taxes Act 1988. The Court of Appeal, Civil Division, in dismissing the taxpayer's appeal, held that, for the purposes of s 74(1)(a) of the Act, the courts had never wavered from the proposition that the business purpose had to be the sole purpose. There was no warrant for distinguishing between the two purposes by assessing one as being intermediate or subordinate to the other.
Corporation tax – Computation of profits. The taxpayer sought to deduct payments made to a rugby club from computation of its profits for corporation tax purposes. The First-tier Tribunal (Tax Chamber) and the Upper Tribunal (Tax and Chancery Chamber) upheld the decision of Revenue and Customs Commissioners to disallow the deductions and found that the payments were not 'wholly and exclusively laid out or expended for the purposes of the trade', pursuant to s 74(1) of the Income and Corporation Taxes Act 1988. The Court of Appeal, Civil Division, in dismissing the taxpayer's appeal, held that, for the purposes of s 74(1)(a) of the Act, the courts had never wavered from the proposition that the business purpose had to be the sole purpose. There was no warrant for distinguishing between the two purposes by assessing one as being intermediate or subordinate to the other.
Update from the Chair of the Bar
By David Green
Mário Barroso, Head of R&D and Method Development at AlphaBiolabs, examines the forensic science underpinning hair drug testing, its evidential scope and limitations, and why it remains the gold standard for evidencing patterns of drug use in family proceedings
Unlocking your aged debt to fund your tax in one easy step. By Philip N Bristow
Clement Cowley, Partner at The Penny Group, discusses the upcoming changes to pensions and Inheritance Tax and the potential impact on your financial future
Save the Children UK is the latest charity to benefit from a £500 donation from AlphaBiolabs via the company’s Giving Back initiative
James McNeill Whistler at Tate Britain until 27 September Rothko in Florence at Palazzo Strozzi until 23 August Reviewed by Stephen Cragg KC
The Chief Legal Officer to the Metropolitan Police, barrister Brett Welch, tells Anthony Inglese CB about his mission and the work to turn the Met around
Barrister apprenticeships – shortly to provide the fourth pathway to the Bar – are an ideal opportunity to support local talent and ‘grow your own’, say Tim Coulson and Dr Jane Dennehy
Grok around and find out – or not? Mariya Peykova investigates the nudification scandal, what the law has to say about sexually explicit deepfakes, and whether stronger regulation is needed
Oliver Lewis spotlights an overlooked yet rapidly evolving area of law – coercive and controlling behaviour within care contexts
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