Not all expenditure incurred by taxpayers in making payments in
response to blackmail or extortion, in the popular meaning of those
words, will be disallowable under ICTA88/S577A (1A). A disallowance
is possible only if there is an offence under the relevant law in
England or Wales, Northern Ireland or Scotland. Some taxpayers,
particularly those with operations abroad, may make payments in
response to blackmail or extortion in the popular sense but there
may be no offence over which the UK has jurisdiction.
FA02 extended S577A to certain criminal payments made outside
the UK but it did not cover those payments within S577A (1A).