BIM45825 - Specific deductions - incidental costs of loan finance: Procuration fees

Where not allowable on general principles, allow under ITTOIA/S58

Procuration or commitment or fees may be incurred as part of the cost of raising business finance. On general principles, such fees may not be deducted if the finance is a permanent addition to capital, but are deductible where the borrowings are temporary and can be regarded as an ordinary incident of carrying on the business (Ascot Gas Water Heaters Ltd v Duff, 24TC171 on page 176).

Where such fees are not allowable on general principles, you should allow any such fees incurred in connection with loans or loan stock under ITTOIA/S58 - BIM45815 bullet point (d).