BIM38295 | Wholly and exclusively: companies: take-over bids: other grounds for disallowance

From HM Revenue & Customs · Business Income Manual

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Gifts, entertainment etc

Expenditure on ensuring that a company’s issued shares do not change hands is capital, but in those circumstances the expenditure will in any event clearly fall foul of the test in (see ).

Where, exceptionally, a deduction is claimed for losses on the sale of shares purchased as part of a (possibly illegal) price support operation, the capital argument may well have independent significance. For losses on disposals of shareholdings where the conditions relating to the substantial shareholdings exemption are met see onwards.

There is detailed guidance on the capital/revenue divide at onwards.

Finally, you should not overlook the disallowance of expenditure on gifts and entertaining under . Such expenses might be incurred, for example, to maintain the loyalty of existing shareholders (see onwards).