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Investment fees on potential stock exchange listing

Question

Our client is an investment company which incurred significant fees in connection with a potential listing on a recognised stock exchange. However the listing did not proceed on account of a lack of investor appetite. The main reason for the listing was to provide an exit for some of the founder shareholders. Are any of those fees deductible for tax purposes?
 

Answer

 
The rules providing for tax relief in respect of management expenses were substantially amended in 2004. The main changes were not only designed to extend the relief to a wider range of companies but also to deny tax relief for capital expenditure. CTA 2009 s 219(1) provides that ‘in calculating the corporation tax to...

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