Summary
Parking fines were held not to be an allowable deduction in computing a company’s profits chargeable to corporation tax.
Background
The appellant, a secure cash transportation company, provided cash delivery and collection services. Its principal activity comprised the secure delivery and collection of cash to and from customers’ premises (i.e. ‘cash in transit’), and replenishment of ATMs together with related activities (i.e. ‘cash and valuables in transit’).
The appellant incurred substantial amounts in parking fines (i.e. penalty charge notices (PCNs)), and claimed a deduction for those costs in calculating its profits chargeable to corporation tax for a number of accounting periods. HM Revenue and Customs (HMRC) made discovery assessments and issued tax return enquiry closure notices, disallowing the
