BIM42115 - Deductions: scope of: sole purpose

The purpose must be solely for the business

For an expense to qualify under ICTA88/S74 (1)(a), the business purpose must be the sole purpose. Where there is no objective yardstick by which any business element can be distinguished from the non-business element, a non-trade or private purpose precludes deduction from trading profits in full (see Newsom v Robertson, 33TC452, (see BIM37605); Knight v Parry, 48TC580, (see BIM37960); Murgatroyd v Evans Jackson, 43TC581, (see BIM37950); Prince v Mapp, 46TC169, (see BIM37945); Caillebotte v Quinn, 50TC222, (see BIM37660); Sargent v Barnes, 52TC335, (see BIM37630) and Watkis v Ashford, Sparkes & Harward, 58TC468, (see BIM37925)). But see BIM42130 regarding circumstances in which a sum may be apportioned.