BIM46510 - Specific deductions: provisions: allowability for tax

A provision made in accounts is the recognition of an expense or liability the timing or amount of which is uncertain. This follows its accountancy meaning. Provisions are distinguished from trade creditors and accruals and are reported separately in accounts. The word is also often used to refer to the recognition of reduction in value of an asset, for example, a bad debt provision or a stock provision. The rules governing such ‘provisions’, both in accountancy practice and tax law, are different, and covered elsewhere in this guidance (stock valuation BIM33100 onwards, bad debts BIM42700 onwards).

A provision made in accounts will only be allowable for tax purposes if:

  • It is in respect of allowable revenue expenditure and not for example, in respect of capital expenditure see RTZ Oil & Gas Ltd v Elliss [1987] 61TC132.
  • It is in accordance with UK GAAP, including FRS12.
  • It does not conflict with any statutory rule governing the time at which expenditure is allowed.
  • It is estimated with sufficient accuracy see BIM46555.