The issue in this appeal was whether Scottish Power are entitled, when calculating profits for the purpose of the corporation tax charge, to deduct sums paid to various customers and charities pursuant to settlement agreements made between SPERL and the energy regulator, GEMA.
The Supreme Court has held the the Upper Tribunal was correct in assessing that this was not possible.
David Ewart KC and Thomas Chacko acted for HMRC.
You can read a copy of the judgment here.
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