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Argument continues
KEY POINTS
- Payments made to acquire partnership interests were trading in nature.
- An alternative argument not in the closure notice was open to HMRC.
- Upper Tribunal invited further argument on the issue.
- Important to consider the economic and business reality of expenditure.
The Upper Tribunal has held that payments for acquisitions of partnership interests are deductible in calculating the profits of the partners’ solo trades of dealing in those partnership interests set out in CRC v Investec Asset Finance plc and another. The payments were revenue expenditure and were incurred wholly and exclusively for the purposes of the trades. But later capital contributions to the partnerships were not deductible because they were made partly for the purposes of the partners’ solo trades of dealing in the partnership interests and partly for the...
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