For updates affecting this Division please see Part B0 Updates
Expenditure incurred for the purposes of the trade
B2.315 The concept of wholly and exclusively
The tax legislation provides that no deduction is generally available for any expense which is not wholly and exclusively incurred for the purposes of the trade1. ITTOIA 2005 and CTA 2009 do not attempt to set out a test for determining whether expenditure is 'wholly and exclusively' incurred for this purpose.
The question whether expenditure is capable of satisfying the 'wholly and exclusively' test has been held to be one of law2.
Once this is established, it is a question of fact whether it is incurred wholly and exclusively for the purposes of the trade3.
Even where it can be determined that an item of expenditure has been incurred
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