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HMRC internal manual

Corporate Intangibles Research and Development Manual

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Core computational rules: deductible debits: general matters and adjustments for tax purposes: disallowance of expenditure: criminal payments

CTA09/PART8/S865 (3)(c)

Exceptionally, debits otherwise deductible under Part 8 may arise in respect of expenditure within CTA09/S1304. That is expenditure:

  • in making a payment which constitutes a criminal offence, or
  • in making a payment induced by blackmail or extortion.

Section 865 (3)(c) ensures that debits of this nature are disallowed. The guidance at BIM43100 onwards should be applied in identifying these payments.