The appeal

No. 36 Queens Gate Limited (the Appellant) appeals against three assessments to corporation tax. Details are:

There was no dispute between the parties as to the figures. The assessments assessed corporation tax under Case III of Schedule D on interest received. The Appellant sought to deduct management expenses from the interest before it was taxed.

The issue

The issue for determination in the appeal was whether the Appellant was an investment company as defined by section 130 of the Income and Corporation Taxes Act 1988 (the 1988 Act) and therefore entitled to relief for management expenses under the provisions of section 75(1) of the same Act.

The statutory provisions

Section 75(1) provides:

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