[BIM35620] BIM35620 – Capital/revenue divide: intangible assets: making good dilapidations as a condition of the lease
There can be more than one way of achieving a particular result. The tax consequences follow from the route chosen. You should not accept that the tax consequences should be determined as if a different route to that actually followed had been adopted. If a taxpayer achieves their end by means of capital expenditure then the cost is disallowed. That the same end could have been achieved by revenue expenditure does not convert actual capital expenditure into a revenue deduction.