Chancery Division.

Judgment delivered 28 July 1982.

Corporation tax – Deductible expenditure – Whether ex gratia payments wholly and exclusively expended for the purposes of taxpayer’s trade – Whether payments of capital or income nature – Income and Corporation Taxes Act 1970, sec. 130(a).

  The taxpayer companies were regional operating subsidiaries of Watney, Mann & Truman Holdings Ltd. (‘Watney Mann’). The taxpayer companies owned on-licence premises occupied (1) by tied tenants (2) by companies in the same group as themselves (‘managed houses’).

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