CTM17600 | Distributions: purchase of own shares: legal costs

From HM Revenue & Customs · Company Taxation Manual

The legal costs a company incurs in a purchase of own shares are generally disallowable in computing the company's trading income. This is on the grounds that they are:

  • capital expenditure in respect of the company's share capital, or

  • within (no deduction alowed for items of a capital nature).

The expenditure is also likely to fail the wholly and exclusively test under .

For relevant case law references concerning relief for costs of share capital reorganisations and reconstructions see .