The general rules in the Taxes Acts about deductions are written
in negative terms which say what is not to be deducted - see
BIM42051. However these prohibitions are
over-ridden in some circumstances by specific legislation, which
provides for a deduction or allowance for a sum which would
otherwise be prohibited. These exceptions have usually been
introduced because wider policy considerations have indicated that,
in specified circumstances, a general principle should be set aside
- see
BIM42080.
An example of an over-ride to a general prohibition is to be
found in ICTA88/S77 (see
BIM45815) which gives relief for certain
cost of raising loan finance. Costs that would otherwise be
disallowed on the grounds that they are capital. Another example is
in ICTA88/S91 that allows a measure of relief for the (otherwise,
again capital) cost of land used in the trade of cemetery operator
- see
BIM52501.
