Chancery Division.

[The appeal against this decision is reported at [1983] BTC 406.]

Judgment delivered 8 December 1982.

Corporation tax – Whether expenditure on capital or revenue account – Payment made to secure modification of restrictive terms associated with loan arrangement – Whether payment secured any asset of an enduring nature – Income and Corporation Taxes Act 1970, sec. 130(f).

  This was an appeal by the Crown from a decision of the Special Commissioners. The Commissioners had found that a payment of £20,000 by the taxpayer company was on revenue account; the Crown contended that it was of a capital nature.

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