12 Expenditure incurred before qualifying activity carried on

12  Expenditure incurred before qualifying activity carried on

[(1)]     For the purposes of this Part, expenditure incurred for the purposes of a qualifying activity by a person about to carry on the activity is to be treated as if it had been incurred by him on the first day on which he carries on the activity.

[(2)     Subsection (3) applies if—

(a)     a company that does not have a Northern Ireland

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