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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Wholly and exclusively: companies: take-over bids: nature of company incurring expenditure

S54 Corporation Tax Act 2009

Investment or trading company?

Depending on the nature of a group’s activities and how they are organised, defence expenses may be incurred either by a trading company or by an investment company.

Where a company carries on activities falling in more than one of these categories (eg an investment company with an ancillary trade of providing management services), it is important to establish the precise grounds on which it is contended that the expenditure is deductible.

Trading companies are discussed at BIM38275 onwards.

Investment companies are discussed at BIM38297.