387. Relief for pre-trading expenditure.

In general, where a company incurs expenditure for the purposes of a trade1, before the date on which the company starts to carry it on ('the start date') and the expenditure:

  1.  

    (1)     is incurred not more than seven years before that date; and

  2.  

    (2)     is not otherwise allowable as a deduction in calculating the profits of the trade but a deduction would be allowed for it if incurred on the start date;