Share-capital issue expenses include Registrar fees, allowing preliminary-expenditure amortisation where shares are issued to a holding company.
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....Fees paid to the Registrar of Companies for increasing share capital through shares issued to a holding company qualify for amortisation as preliminary expenditure. The provision covers expenditure incurred in connection with the issue of shares; it is not confined to expenses relating to a public subscription. The enumerated expenses are descriptive, and the comma after "issue" prevents a restrictive reading that would exclude Registrar fees. Accordingly, disallowance of the claimed amortisation was unsustainable, and amortisation of the share-capital issue fees was allowed.....
TaxTMI