Mr Stephen Oliver QC and Mr THK Everett.

Decision released 22 November 1995.

Corporation tax – Deduction in computing profits – Sponsorship payments – Recruitment consultant sponsored competition horses owned and ridden by majority shareholder’s wife and children – Company obtained publicity at horse shows and show-jumping events – Dual purpose of expenditure – Expenditure was not incurred wholly and exclusively laid out for the purposes of trade – Appeal dismissed – Income and Corporation Taxes Act 1988, s. 74(a).

David Ewart, counsel instructed by Higginsons, chartered accountants, for the taxpayer.

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