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Home / Simons-Taxes /Corporate tax /Part D7 Financial service sectors /Division D7.3 Companies with investment business, investment companies and investment trusts /Deductible management expenses / D7.310 Deductibility of management expenses—decided cases
Commentary

D7.310 Deductibility of management expenses—decided cases

Corporate tax

In Capital and National Trust Ltd1, it was held that sums disbursed by an investment company for brokerage and stamp duty in changing its investments were not management expenses within what is now CTA 2009, s 1219. Cases often consider the distinction between capital and non-capital items, such as expenses incurred to assist with investment decision making (more likely to be management expenses) as opposed to implementation (more likely to be capital). The following are further items which have not been allowed as management expenses:

  1. Ìý

    •ÌýÌýÌýÌý loss on exchange on providing currency to meet the interest on the bonds of the company making the claim2

  2. Ìý

    •ÌýÌýÌýÌý cost of issuing new debentures to replace existing charges3

  3. Ìý

    •ÌýÌýÌýÌý part of the fees of a property holding company's surveyor and assistant surveyor4

  4. Ìý

    •ÌýÌýÌýÌý cost of advertising for tenants by a property holding company5

  5. Ìý

    •ÌýÌýÌýÌý part of the fees of an investment company's directors found as a fact not to have been disbursed as management expenses6

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Web page updated on 17 Mar 2025 16:12