Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Dual purpose sponsorship

09 July 2010
Issue: 4263 / Categories: Tax cases , Business
Interfish Ltd (TC520)

The taxpayer company Interfish was incorporated in 1977 and owned and controlled by C. He was keen on rugby and the company made substantial sponsorship payments to the local club.

The owner also became heavily involved in running the club being instrumental in making it more successful. He said he wanted to do this because it would help raise the profile of his company and make him well-known in the local business community.

The company claimed the sponsorship payments made by Interfish to the rugby club were deductible as expenses incurred wholly and exclusively for the purposes of the business (TA 1998 s 74(1)).

HMRC refused the claim on the basis that it had a dual purpose: the payments were at least in part to support the club and enable C to pursue his interest in it.

The First-tier Tribunal said...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon