PM163450 - Costs connected with the capital structure of a business

Fees incurred in connection with the acquisition, alteration or enhancement of how the ownership of a business is structured should generally be disallowed as the costs are regarded as capital expenditure for tax purposes. This will include costs incurred on:

• forming, varying or dissolving a partnership
• the incorporation of a partnership’s business (to a limited company)
• partnership becoming a limited liability partnership (LLP)

Further guidance is available at BIM35525.