I read with interest Richard Curtis' article 'Jump into a Jersey' (Taxation, 19 January 2006, page 389). Naturally enough, this focused on the tax implications of operating a bank account in Jersey, but in practice general law considerations can be far more important.
I have just got round to reading John's article on page 123 of Taxation, 3 November 2005. He says that BIM 45700 allows borrowing against revaluation reserve. In Example 3 it specifically says that it does not:
I have read your editorial (Taxation, 27 October 2005, page 83) concerning HMRC v William Grant & Sons, Distillers. I am not sure that I can agree with your conclusion that the majority view of the Court of Session is in error.
It seems to me that the purpose of the add-back of depreciation is to establish the profit before any deduction for 'any sum employed or intended to be employed as capital in the trade' i.e. the 'consumption' of the fixed assets.