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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Computation: interaction with other taxes: IT: exclusion of expenditure

TCGA92/S39 (2) makes clear that no expenditure of a revenue nature is allowable. It expressly prohibits the allowance of any sum which would have been deducted in computing the profits of a trade, if the asset in question had been a fixed asset in use for the purposes of the trade. See Emmerson v Computer Time International Ltd (in liquidation), 50TC628.