Thank you for sharing!

Your article was successfully shared with the contacts you provided.

The Inland Revenue has decided not to appeal against the decision of the Special Commissioners, given on 31 May, in a landmark case involving four building societies that converted from mutual status to banks. At stake was nearly half a billion pounds of costs that had been incurred by the Woolwich, Halifax, Northern Rock and Alliance and Leicester. In all four cases, the Inland Revenue had disallowed deductions in respect of the costs of conversion, and contended, first, that the sums incurred were not incurred wholly and exclusively for the purposes of the trade and, secondly, that the expenditure was capital in nature (See section 74 (1), Income and Corporation Taxes Act 1988). The cases were heard sequentially, with Halifax plc v Davidson [2000] STC (SCD) 251 being the first. As the Halifax served as the base case for legal argument (with variances only being addressed in the other three cases), this article focuses mainly on the Halifax.

This premium content is reserved for
Legal Week Subscribers.


  • Trusted insight, news and analysis from the UK and across the globe
  • Connections to senior business lawyers within the leading law firms and legal departments
  • Unique access to ALM's unrivalled, market-leading reporting in the US and Asia and cutting-edge research, including Legal Week's UK Top 50 and Global 100 rankings
  • The Legal Week Daily News Alert, Editor's Highlights, and Breaking News digital newsletters and more, plus a choice of over 70 ALM newsletters
  • Optimized access on all of your devices: desktop, tablet and mobile
  • Complete access to the site's full archive of more than 56,000 articles

Already have an account?

For enterprise-wide or corporate enquiries, please contact Paul Reeves on Preeves@alm.com or call on +44 (0) 203 875 0651


Legal Week Newsletters & Alerts

Sign Up Today and Never Miss Another Story.

As part of your subscription, you can sign up for an unlimited number of a wide range of complimentary newsletters and alerts. Get the timely legal news and critical analysis you cannot afford to miss. Tailored just for you. In your inbox. Every day.

Copyright © 2019 American Lawyer Media International, LLC. All Rights Reserved.