BIM42526 - Specific deductions: administration: own training courses
Provided it is incurred wholly and exclusively for the purposes
of the trade carried on by the individual at the time the training
is undertaken, expenditure on training courses attended by the
proprietor of a business (either as a sole trader, or in
partnership with others) with the purpose of up-dating their skills
and professional expertise is normally revenue expenditure, which
is deductible from profits of the business.
The text of an article on this subject published in TB1G in
November 1991 is reproduced at
BIM35660.
Business purpose test
In considering the question of purpose, you should not take an unduly narrow view of whether the content of any particular course only up-dates existing skills of the individual. But if it is clear that, for example, a completely new specialisation or qualification will be acquired as a result of the expenditure, it is unlikely that the expenditure will be wholly and exclusively for the purposes of the existing trade. For general discussion of business purpose see BIM37050 onwards.
Capital test
Expenditure on new skills etc may also be capital if what is acquired can be viewed as an identifiable asset of sufficient substance and endurance. For more on the circumstances in which expenditure on intangible assets may be capital see BIM35500 onwards.
