CTM08300 | Corporation Tax: management expenses: raising finance
From HM Revenue & Customs · Company Taxation Manual
The expenses incurred by a company with investment business on obtaining business finance, meaning raising capital in the broad sense, whether in terms of loans, shares or other products, are not expenses of management within . The same principle applies to interest paid on loans.
The authority for these conclusions is variously in
London County Freehold and Leasehold Properties Ltd v Sweet (1942) 24TC412,
Hoechst Finance Ltd v Gumbrell (1983) 56TC594, and
Bennett v Underground Electric Railway of London Ltd (1923) 8TC475.
There is useful discussion in Howden Joinery Group plc and another v HMRC [2014] UKFTT 257 (TC). Some relief may be provided under the loan relationships legislation in . For details of the loan relationships legislation see the HMRC Corporate Finance Manual ( onwards).