The taxpayer company became a sponsor of a local rugby club to which the firm made a series of payments. It claimed a deduction in its profits for corporation tax.
HMRC refused the claim on the basis the payments had a dual purpose: they benefitted the club as well as the company.
The First-tier Tribunal dismissed the taxpayer’s appeal against the Revenue’s decision. The case returned to the same tribunal for a ruling on what sums if any could be apportioned.
The company and the taxman had agreed that expenditure on hoardings at the rugby club’s ground would be allowed as a deduction.
The items remaining in dispute included logos on players’ shirts promotion of the taxpayer firm on tickets and programmes access to hospitality facilities availability of players to promote the company’s business and access to key business figures.
HMRC said...
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