| 释义 |
duality
n. A principle of UK income tax and corporation tax under which expenditure is not deductible in computing the profits subject to tax if the expenditure has a dual purpose. A deduction in computing trading profits is denied for any expense not incurred wholly and exclusively for the purposes of the trade. In Mallalieu v Drummond [1983] UKHL TC 57, Mallalieu was a barrister who sought to deduct the cost of clothes bought to wear in court, such clothes being required by rules of court etiquette. The House of Lords held that the clothes performed the function of providing warmth and decency to Miss Mallalieu, as well as satisfying the court rules. This duality of purpose denied a deduction for the expense of purchasing the court clothes. The duality principle refuses relief by apportionment of a payment but permits relief where a wholly business expenditure can be identified by dissection of a payment (Gazelle v Servini [1995] STC 324). |