The decision overturns that of the First-tier Tribunal (FTT) which ruled that the investment company Centrica Overseas Holdings Limited (COHL) was not entitled to corporation tax deductions for fees relating to advice on a potential disposal of assets as the decision to dispose was taken by its parent company and not the investment company.

COHL was the intermediate holding company in the corporate group of energy company Centrica plc, which claimed a corporation tax deduction for expenditure on the fees of three companies in connection with the disposal of its investment in Dutch energy business Oxxio BV.  Those companies were, Deutsche Bank AG, PwC and De Brauw Blackstone Westbroek.