Colin Bishopp

Decision released 5 August 2008

Income tax – director's personal guarantee of company's debts – director resigned from directorship and left company – guarantee then called on – whether payment made by director an allowable deduction – ITEPA 2003 s. 336 – whether conditions satisfied – no – appeal dismissed


A payment by the taxpayer on his personal guarantee as the director of a company was not an allowable deduction under ITEPA 2003, s. 336(1) since it was not incurred wholly, exclusively and necessarily in the performance of the duties of his employment.


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