Vaines v CRC, Court of Appeal, 25 January 2018
Purpose of payment made by partner
The taxpayer was a partner in law firm Haarmann Hemmelrath until the end of 2005 when the London office was acquired by Squire Sanders & Dempsey (SSD) and he became a partner there.
In October 2009 he claimed a deduction of £215 455 under ITTOIA 2005 s 34 (‘Expenses not wholly and exclusively for trade and unconnected losses’) against his professional income from SSD. It related to a payment he had made to a German bank (BL) under an agreement made by various individuals who had been connected with Haarmann Hemmelrath. When that firm ceased to trade it left debts of €17m to several banks. BL sued the UK partners of Haarmann for payment. The taxpayer negotiated an agreement to pay €300 000 to BL to release him from all claims to the bank. He paid this in January 2008. He...
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