An investment company incurs professional fees in assessing the expected profitability of buying a new investment property. The company decides to go ahead with the purchase, however, the purchase falls through. The solicitor's conveyancing fees are clearly capital and are a "tax nothing", but is this also true of the professional feasibility fees?
Additionally, surveyors fees are incurred, and arguably these are also also part of the feasibility work. Should these be revenue too?
I have been looking through the HMRC manual section on capital/revenue divide (BIM35000), but I haven't found anything that addresses this point. I have also spoken with an adviser at Markel tax who said he believe that they were capital, however, he didn't seem certain and this goes against my instinct that they are revenue. If anyone could offer an opinion, or provide a link to an authoritive source that gives the answer, that would be great.
Thanks, Chris
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You'll find more relevant information (in both senses) at CT08260.
Thanks Richard. I can't find that page in the manual, would you mind just confirming that reference?
I hope you're well by the way! I think we briefly worked together at GBP.
I’m not Richard, but
https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm08260