BIM47100 - Specific deductions: staffing costs: share of profits
Remuneration to an employee (including a director of a company)
calculated as a share of the profits of the business as a whole is
normally allowable as a deduction. (See Stott and Ingham v
Trehearne [1924] 9TC69, where remuneration so calculated was in
part allowed.)
A deduction will therefore normally be allowed for
remuneration taking the form of bonuses under a co-partnership or
profit sharing scheme (as distinct from dividends, interest or
bonuses on co-partnership stock).
In an exceptional case payments described as remuneration may
in fact be distributions of profits after they have been earned,
and so not a deductible expense of earning the profits (see,
however, British Sugar Manufacturers Ltd v Harris [1937]
21TC528).
