Section 61 — Corporation Tax Act 2009: Pre-trading expenses

Pre-trading expenses 61 1 This section applies if a company incurs expenses for the purposes of a trade before (but not more than 7 years before) the date on which the company starts to carry on the trade (“the start date”).

2 If, in calculating the profits of the trade—

a no deduction would otherwise be allowed for the expenses, but b a deduction would be allowed for them if they were incurred on the start date, the expenses are treated as if they were incurred on the start date (and therefore a deduction is allowed for them).

3 This section does not apply to any expenses in relation to which—

a any debit falls, or b any debit would fall but for section 330 (loan relationships: debits in respect of pre-trading expenditure), to be brought into account for the purposes of Part 5 (loan relationships).