In Centrica Overseas Holdings Limited v HMRC [2022] EWCA Civ. 1520 the Court of Appeal (CoA) was unanimous in reversing the decision of the Upper Tribunal (UT) determining that adviser fees incurred by an intermediate UK holding company (COHL) in the Centrica Plc group were deductible expenses of management under the UK equivalent of s83 TCA 1997. The UT decision was reviewed in “Direct Tax Cases: Tax Appeals Commission Determinations”, Irish Tax Review, 34/4 (2021).
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