Hoechst Finance Limited v Gumbrell (H.M.Inspector of Taxes). 1983 BTC 62
Court of Appeal.
Judgments delivered 20 January 1983.
Corporation tax – Expenses of management of investment company – Annual commission payable to parent company as consideration for guarantee for repayment of loan – Money raised to invest by way of advances in group companies in UK – Whether an expense of management – Income and Corporation Taxes Act 1970, sec. 304(1).