All business expenditure is likely to be made with the intention of securing some commercial advantage (see Lord Reid's remarks in Commissioners of Inland Revenue v Carron Co [1968] 45TC18 quoted in BIM35565). To establish whether expenditure is capital or revenue, you have to establish the effect of the expenditure and how long it will likely endure. Where the expenditure is on an intangible benefit or advantage (for example, trading agreements, licences or other intangibles (see BIM46415)) you need to establish whether the identifiable asset is sufficiently substantial and enduring to count as capital.

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