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From Reimbursements to Revenue: The Tax Re-Characterisation Risk After BNS v Comptroller of Inland Revenue
November 26, 2025by Dr Dawkins Brown
For years, “reimbursement” has been one of the most comforting words in intragroup accounting. If a local branch or subsidiary simply “reimburses” head office or a regional hub for costs incurred on its behalf—at cost, with no margin—surely that is tax neutral? No profit, no gain, no income. Just a wash-through number. The recent decision...
