S34 Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005), S54 Corporation Tax Act 2009 (CTA 2009)

The trade purpose must be the only purpose

To qualify for a deduction from trading profits under S34(1)(a) ITTOIA 2005 (for unincorporated businesses) and S54(1)(a) CTA 2009 (for companies), the trade purpose of the expense must be the sole purpose. A non-trade or private purpose precludes deduction in full where there is no objective yardstick by which any trade element can be distinguished from the non-trade element.

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