In Interfish Ltd v HMRC (Upper Tribunal – 22 July) a company which carried on business in the fishing industry made substantial sponsorship payments to a rugby club. It claimed that these should be allowed as deductions in computing its profits. HMRC rejected the claims on the grounds that the payments were not wholly and exclusively for the purpose of the company’s business but were partly made because the company’s controlling director was very keen on rugby and wanted to strengthen the club. The First-tier Tribunal dismissed the company’s appeal against this decision finding that the payments had been made with a dual purpose and the Upper Tribunal upheld this decision as one of fact. Birss J held that Judge Paines had been entitled to find that the company had a dual purpose in making the payments.
In Interfish Ltd v HMRC (Upper Tribunal – 22 July) a company which carried on business in the fishing industry made substantial sponsorship payments to a rugby club. It claimed that these should be allowed as deductions in computing its profits. HMRC rejected the claims on the grounds that the payments were not wholly and exclusively for the purpose of the company’s business but were partly made because the company’s controlling director was very keen on rugby and wanted to strengthen the club. The First-tier Tribunal dismissed the company’s appeal against this decision finding that the payments had been made with a dual purpose and the Upper Tribunal upheld this decision as one of fact. Birss J held that Judge Paines had been entitled to find that the company had a dual purpose in making the payments.
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