Littlewoods Mail Order Stores v Inland Revenue Commissioners [1969] 1 WLR 1241 is a UK company law case concerning piercing the corporate veil.

Its premises were on a 99-year lease for £23,444 a year from a charity called Oddfellows Friendly Society.

It came to this: the Oddfellows transferred the freehold in Jubilee House to the Fork Manufacturing Co. Ltd., which was a wholly owned subsidiary of Littlewoods.

On the other hand, Littlewoods would claim to deduct the full rent of £42,450 from their profits instead of the smaller sum of £23,444.

Plowman J held that the rent payments by Littlewoods were of a revenue character and properly deductible, but relying on a case that was soon reversed by the House of Lords.

Sachs LJ and Karminski LJ held that FM’s interposition made no difference to the real nature of the payments, the transfers were not ‘money wholly and exclusively laid out’ for the purpose of trade and not deductible.

Lord Denning MR held more broadly that the wholly owned subsidiary was not in this case a separate legal entity.