I have a small limited company client who engaged in a particular transaction in the financial year just passed. The company sold its commercial property to a pension fund (director's SIPP) at market value. To fund the purchase of the property, the fund obtained a bank loan and also a one-off contribution to the fund from the limited company.
Will the contribution:
(a) be disclosed as an exceptional item in the P&L
(b) be deductible for corporation tax purposes
I am assuming the "wholly and exclusively" rule applies which may mean the contribution (c£70k) is disallowed?