[2014] EWCA Civ 876

Court of Appeal (Civil Division)

Lord Dyson, Master of the Rolls, Lord Justice Moses and Lord Justice Patten

Judgment delivered 27 June 2014

Corporation tax – Deductibility of expenditure – Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 74 – Sponsorship payments – Dual purpose of benefiting sports club and taxpayers trade – Payments not deductible – Appeal dismissed.

  The Court of Appeal upheld the decision of the Upper Tribunal that sponsorship payments made by a company to a rugby club were not made wholly and exclusively for the purposes of the companyʼs trade.


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