The enactment of the Corporation Tax Act 2009 has clarified for corporation tax purposes a previously uncertain and sometimes inconsistent application of the ‘wholly and exclusively’ principle. CTA 2009, s. 54(2) states the following:

‘If an expense is incurred for more than one purpose, this section does not prohibit a deduction for any identifiable part or identifiable proportion of the expense which is incurred wholly and exclusively for the purposes of the trade.’

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