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HMRC internal manual

Business Income Manual

Waste disposal: site restoration: expenditure not allowable

S168 Income Tax (Trading and Other Income) Act 2005, S145 Corporation Tax Act 2009

No deduction is allowable for any part of a site restoration payment (see BIM67540) that represents:

  • expenditure allowed as a deduction for any period before that in which the payment was made;
  • expenditure that qualifies for capital allowances.

No deduction is allowable if the payment arises from arrangements to which the trader is a party and the main purpose, or one of the main purposes, of the arrangements is to obtain a deduction under the site restoration provisions.