71. Trading receipts.

Receipts of a capital nature are excluded from the computation of trading profits1. Such items will fall to be taxed, if at all, under the capital gains or capital allowances legislation2. A payment relating to the sterilisation of a capital asset3 or relating to the whole structure of the taxpayer's profit-making apparatus will be capital4.

Receipts of a capital nature are brought into account as a receipt in calculating the profits of the trade on the cash basis where the expenditure incurred in acquiring, creating or improving an asset has been brought into account in calculating the profits of a