Just a quick check to see whether my understanding is correct.
Fees incurred regarding the sale of shareholder shares were paid by their close company.
My understanding is as follows:
1. The meeting of the pecuniary liabilities is taxable and nic'able via the payroll and noted on the P11d as a Class 1 NIC item.
2. The payments by the company are effectively salary and so are allowable for CT.
3. The fees are deductible in computing the shareholders CGT liability. This seems to be the case under TCGA 1992 s.38.
I can't quite square how the company can get a CT deduction and the shareholders get a CGT deduction for the same expense.
Happy to be corrected on any of the points noted above.
Thanks in advance.