Court of Appeal.

Judgment delivered 8 November 1983.

Corporation tax – Whether expenditure of capital or revenue nature – 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 taxpayer company from the finding of Vinelott J. (reported at [1983] BTC 28) that a payment of £20,000 was of a capital nature, securing enduring advantages to the company and freeing a large amount of the company’s property from fixed and floating charges over it.

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