BIM42205 - Deductions: timing: no specific statutory rule: exclude capital items
You should not seek to argue that the accounting treatment is decisive in stamping expenditure as capital for tax purposes. Nevertheless the accounting treatment is one of the factors which is relevant in determining the character of the expenditure for tax purposes and in a borderline case it may tip the balance. A claim that expenditure charged to a fixed asset account is a revenue deduction in computing taxable profits should therefore be examined.