MacKinlay v. Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL) -- summary under Paragraph 18(1)(h)

By services, 28 November, 2015

The policy of a firm of accountants was to reimburse its partners for various costs of their moving their residence from one city to another at the request of the executive partnership committee. Lord Oliver stated:

"... It is inescapable as it seems to me, that the expenditure, motivated no doubt by the fact of moving house, which in turn was motivated by the desire to put the partner concerned in a better position to further the interests of the firm, was an expenditure serving and necessarily and inherently intended to serve the personal interests of the partner in establishing his private residence for himself and his family and it cannot be said to be exclusively for the purposes of the partnership practice."

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