“…ve scheme of partnership taxation in the years under appeal, reference may also be made to my judgment (with which Newey and Sharp LJJ agreed) in HMRC v Vaines [2018] EWCA Civ 45, [2018] STC 297, at [14] – [18] and [21].…”
“…e purposes of the trade. They do not mean for the purposes of the taxpayer but for the purposes of the trade, which is a different concept …”. In HMRC v Vaines [2018] EWCA Civ 45, [2018] STC 297, this Court held that expenditure to preserve and protect the reputation of one of the partners was not expenditure wholly and exclusively incu…”