BIM42080 | Deductions: general: interaction between prohibitive and permissive rules
From HM Revenue & Customs · Business Income Manual
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In general, rules which permit a deduction take priority over rules which prohibit a deduction.
The following prohibitive rules, however, take priority over permissive rules.
| section | section | Prohibitive rule | Further guidance |
|---|---|---|---|
| 36 | 1288 | Unpaid remuneration | onwards |
| 38 | 1290 | Employee benefit contributions | |
| 48 | 56 | Car hire | onwards |
| 55 | 1304 | Crime-related payments | onwards |
‘Prohibitive rule’ extends, for this purpose, beyond the list of provisions at to include any provision relating to the calculation of trade profits which might be read as prohibiting or restricting the amount of a deduction.