Executive Network (Consultants) Ltd v O’Connor (HMIT) (1995) Sp C 56
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.