Case law corps

Question 1

Gallagher v Jones (GAAP):

Answer 1

HMRC disputed that tax treatment was not in line with accounting treatment and should follow GAAP. HMRC was successful in this case, even where amounts are not material.
Case concerned finance leased assets

Question 2

Britannia Airways (GAAP):

Answer 2

The choice rests with the taxpaying company as to how GAAP is applied. Only need to prove that was have been done is acceptable, not for HMRC to argue otherwise.

Question 3

Duality of purpose (wholly and exclusively) case

Answer 3

Interfish Ltd v HMRC: require there to be an immediate and direct benefit tot he company for an expense.
This case found the main purpose was for the benefit of the Club and not company