72. Trading expenses.

Capital expenditure is excluded from the computation of trading profits1. Such expenditure will be eligible for relief, if at all, under the capital gains or capital allowances legislation2. The distinction between capital and income is sometimes a fine one3. Expenditure made once and for all with a view to the bringing into existence of an asset or advantage for the enduring benefit of the company's trade is attributable to capital4.

In calculating the profits of a trade on the cash basis, no deduction is allowed for items of a capital nature, except for expenditure that would be qualifying expenditure within