Section 147 — Corporation Tax Act 2009: Deduction for capital expenditure

Deduction for capital expenditure 147 1 This section applies if, in the relevant period, an interest in land in the cemetery or memorial garden is sold with a view to the land being used—

a for the purpose of interments, or b for memorial garden plots.

2 A deduction is allowed for—

a capital expenditure incurred by the trader, or a predecessor, on the purchase of an interest in the land or on the preparation of the land, and b ancillary capital expenditure allocated to the relevant period under section 148 (allocation of ancillary capital expenditure).

3 But no expenditure is to be brought into account—

a under both paragraphs (a) and (b) of subsection (2), ... b under both subsection (2)(a) above and section 170(2)(b) of ITTOIA 2005 (relief for income tax purposes) or under both subsection (2)(b) above and section 170(2)(a) of ITTOIA 2005, or c under both subsection (2)(b) above and section 149B(4), 149C(4) or 149D(3). whether for the same or different periods of account.

4 Any purchase price paid on a sale in connection with a change in the persons carrying on the trade is ignored in calculating the amount of the deduction.

5 No deduction is allowed for any expenditure which is excluded by section 149 (exclusion of expenditure met by subsidies).