• Home
  • Business taxes
  • Personal taxes
  • Capital taxes
  • International
  • VAT
  • Tax admin
  • Resources
  • Books
  • About
  • Contact
Claritax News
  • Home
  • Business taxes
  • Personal taxes
  • Capital taxes
  • International
  • VAT
  • Tax admin
  • Resources
  • Books
  • About
  • Contact
  • Business taxes
  • Personal taxes
  • Capital taxes
  • International
  • VAT
  • Tax admin
Claritax News

CT – expenses of management – Court of Appeal – HMRC v Centrica Overseas Holdings Ltd – [2022] EWCA Civ 1520

28 Nov 2022

The Court of Appeal accepted that certain disputed expenses were expenses of management, but ruled in HMRC’s favour on the basis that the expenditure was capital in nature and that it was therefore taken out of the management expenses regime by virtue of CTA 2009, s. 1219(3)(a):

“In my judgement, the UT fell into error … because they considered that the test for expenses of management and the capital expenditure test are similar. Accordingly, they considered that expenses of management are likely to be revenue expenses. I respectfully disagree. As I have explained when setting out the correct statutory interpretation of section 1219(3)(a) of the CTA 2009, in my view the clear intention of Parliament was to carve out of the expenses of management regime those expenses which are capital in nature by reference to the well established principles which have been developed by the courts on that distinct legal question over the course of the last century.”

https://www.bailii.org/ew/cases/EWCA/Civ/2022/1520.html

Latest articles (all topics)

  • How to get authorised to act as a tax agent on behalf of your clients – HMRC update guidance
  • Compliance checks: prohibition of promotion of certain tax avoidance schemes – HMRC publish factsheet CC/FS91
  • R&D tax credits – HMRC publish official statistics
  • HMRC put agent reference number checks on hold until 17 November
Read more

Weekly email alerts

Sign up here for this free service.

wide banner

Recent Posts

  • How to get authorised to act as a tax agent on behalf of your clients – HMRC update guidance
  • Compliance checks: prohibition of promotion of certain tax avoidance schemes – HMRC publish factsheet CC/FS91
  • R&D tax credits – HMRC publish official statistics
  • HMRC put agent reference number checks on hold until 17 November
  • Make a voluntary disclosure to HMRC – HMRC update guidance

Recent Comments

No comments to show.

©2026 All Rights Reserved

Terms & Conditions | Privacy

Copy