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HMRC internal manual

Business Income Manual

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.

  • For detailed guidance on the capital/revenue borderline see BIM35000.
  • For deferred revenue expenditure see BIM42215.