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Chapter LAM04030

Document Cited in Related
Vincent
Published date05 August 2019
Record NumberLAM04030
CourtHM Revenue & Customs

FA12/S81 brings within ordinary BLAGAB management expenses certain expenses which would not otherwise be regarded as such. They must still meet the first two basic conditions set out in FA12/S77(2) (see LAM04020), broadly being expenses of management debited in accordance with generally accepted accounting practice, which are referable to BLAGAB.

Several provisions of CTA09 which treat particular expenses as expenses of management in the case of companies with investment business are adopted as “relevant permissive rules”. These expenses can then be treated as ordinary BLAGAB management expenses for the purposes of FA12/S76. These all relate to expenses which are deductible expenses for companies generally.

The relevant CTA09 provisions are as listed in FA12/S81(3) are:

  • S1000 (costs of setting up employee share ownership trust
  • S1234 (payments for restrictive undertakings)
  • S1235 (employees seconded to charities and educational establishments)
  • S1237 (counselling and other outplacement expenses)
  • S1238(1) to (3) (retraining courses)
  • S1239 to S1242 (redundancy payments and approved contractual payments), subject to a restriction where additional redundancy payments are regarded as FA12/S79 acquisition expenses (FA12/S81(5))
  • S1243 (payments made by the Government)
  • S1244 (contributions to local enterprise organisations or urban regeneration companies), subject to CT009/S1253 disqualifying benefit adjustment

Expenses in connection with contaminated or derelict land CTA09/S1161-2

Land remediation relief...

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