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We act for a UK company which has one director who is also the sole shareholder. There are no other employees. The principal activity of the company is general support and provision of architectural/interior design services. The director/shareholder will be providing these services and this September she has enrolled with a recognised college for a year to study either on a full time or sandwich course relating to her profession. Thus she will be training as well as providing services to third-party customers. There is neither a contract of service nor a contract of training between the director and the company.
The question is whether the company can pay £15 000 for the academic year 2005-06 towards her lodging subsistence and travelling costs under HMRC's Statement of Practice 4/86?
Will the company be able to obtain tax relief for this payment against its profits? In...