Specific deductions: professional fees: other loans
Fees connected with raising, repaying or replacing long-term finance - capital
Outside certain trades in the financial sector, fees incurred in connection with raising, repaying or replacing long-term finance, or rearranging the terms on which such finance is borrowed are capital on general principles, see:
- Texas Land and Mortgage Co v Holtham  3 TC 255 (see BIM35580)
- Montreal Coke & Manufacturing Co Ltd v Minister of National Revenue (Canada)  1 All ER 743
- Whitehead v Tubbs (Elastics) Ltd  57 TC 472 (see BIM35575)
For the borderline between finance that is an ordinary day-to-day incidence of carrying on the business and long-term finance, see Beauchamp v Woolworths PLC  61 TC 542.
The cost of transferring a mortgage on business premises is capital, see Small v Easson  12 TC 351.
However, there is a statutory relief for many of the incidental costs incurred in relation to loan finance, see BIM45800 onwards.