Section 147 | Deduction for capital expenditure

(1)This section applies if, in the relevant period, an interest in land in the cemetery or memorial garden is sold with a view to the land being used—

(a)for the purpose of interments, or

(b)for memorial garden plots.

(2)A deduction is allowed for—

(a)capital expenditure incurred by the trader, or a predecessor, on the purchase of an interest in the land or on the preparation of the land, and

(b)ancillary capital expenditure allocated to the relevant period under section 148 (allocation of ancillary capital expenditure).

(3)But no expenditure is to be brought into account—

(a)under both paragraphs (a) and (b) of subsection (2), ...

(b)under both subsection (2)(a) above and section 170(2)(b) of ITTOIA 2005 (relief for income tax purposes) or under both subsection (2)(b) above and section 170(2)(a) of ITTOIA 2005, or

(c)under both subsection (2)(b) above and section 149B(4), 149C(4) or 149D(3).

whether for the same or different periods of account.

(4)Any purchase price paid on a sale in connection with a change in the persons carrying on the trade is ignored in calculating the amount of the deduction.

(5)No deduction is allowed for any expenditure which is excluded by section 149 (exclusion of expenditure met by subsidies).