[CTM08170] CTM08170 – Corporation Tax: management expenses: wholly and exclusively
There is no wholly and exclusively requirement in CTA09/S1219 and indeed this was confirmed in the case of L G Berry Investments Ltd v Attwooll. The statutory criterion to be applied is whether an expense is an expense of managing the investment business.
L G Berry Investments Ltd v Attwooll 41TC547
The point at issue was whether the company could claim relief for directors' fees as management expenses.