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HMRC internal manual

Business Income Manual

Capital/revenue divide: tax cases and summing up: contents

There is a considerable body of case law on the capital/revenue divide. The courts have developed and refined their approach over a period of more than a century and a half. During the course of this period the art of accountancy has developed from rudimentary beginnings into a well-developed instrument attuned to modern financial requirements.

This chapter offers a summary of what has emerged from the case law dealing with the capital/revenue divide.