The 'wholly and exclusively' rule: To pay or not to pay

Article by Keith M Gordon, barrister, chartered accountant and tax adviser, Atlas Chambers. This article appeared in the March 2007 issue of Tax Adviser. The author discusses the recent decision of the Special Commissioners in AB (A firm) v HMRC that considers the issues of expenditure incurred wholly and exclusively for the purposes of a business, and taxpayers' negligence.

March 2007 by Keith M Gordon

Technical Department
020 7235 9381