You're not wrong, but it's also more complex than that. They could choose to apply "commerciality tests" which include things like whether you're paying over th

You're not wrong, but it's also more complex than that. They could choose to apply "commerciality tests" which include things like whether you're paying over the odds or whether other forms of sponsorship would have a better commercial effect. https://www.gov.uk/hmrc-internal-manuals/business-income-manual/bim42565 https://www.gov.uk/hmrc-internal-manuals/business-income-man... is HMRC's own guidance to its tax inspectors on some of these points. For example, if my company fancied donating £1000 a month to the curl project because we think it's a fantastic tool worth supporting (it is!) but we only use it in a handful of scripts, HMRC might give us some grief if it came up in an inspection. I dare say given the expected technical knowledge of the average tax inspector that a typical HN reader could prevail in such a challenge ;-)