The Commissioners for HM Revenue and Customs v Mr Peter Vaines: [2016] UKUT 0002 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Gammie and Judge Powell on 28 January 2016.
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PARTNERSHIP – whether a member of a limited liability partnership was entitled to deduct a payment of €300,000 (£215,455) to settle German litigation in computing his liability to tax on his share of LLP profits – whether the payment was an expense incurred wholly and exclusively for the purposes of the LLP’s trade or of the individual member’s ‘notional’ trade – whether the payment was revenue or capital expenditure.
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Published 1 December 2016