Corporation Tax Act 2009 section 61

Pre-trading expenses

Section 61 provides relief for business expenses a company incurs before it actually begins trading, by treating them as if they were incurred on the date the trade starts.

  • Expenses incurred for the purposes of a trade within 7 years before the trade starts can qualify for tax relief
  • Qualifying expenses are treated as if they were incurred on the date the trade begins, allowing them to be deducted in calculating trading profits
  • The expenses must be of a type that would have been deductible had they been incurred on the start date itself
  • Expenses that fall within the loan relationships rules (Part 5 of the Act) are excluded from this relief

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