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HMRC internal manual

Capital Gains Manual

Computation: IT: conclusiveness of Income Tax decisions

Any Income Tax determination is conclusive for the purposes of Capital Gains Tax in relation to TCGA92/S37 and TCGA92/S39. Thus, a person cannot claim to have an item of expenditure allowed as a revenue expense for Income Tax purposes and then claim in relation to Capital Gains Tax that it is capital expenditure which should increase the cost of acquisition of the relevant asset.