Redress payments made pursuant to a settlement with an industry regulator were largely non-deductible as being in the nature of penalties, and to the extent that payments were made to charities, they were not deductible as charitable donations.
One of the appellants (SPERL) held gas and electricity supply licences; the other three appellants were holders of electricity generation licences. Between 2010 and 2014, the Office of Gas and Electricity Markets (Ofgem)