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HMRC internal manual

Corporate Intangibles Research and Development Manual

HM Revenue & Customs
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Land Remediation Relief: Capital expenditure: Pre commencement expenditure

FA01/SCH22/PARA1 (3)

CTA09/S1147 (7)

Where a company incurs capital expenditure on qualifying land remediation before it commences its trade or property business, for the purposes of an election to treat the expenditure as a deduction in calculating the profits, the expenditure is treated as having been incurred:

  • on the first day on which the trade or property business commenced, and
  • in the course of carrying on that trade or property business.