Taxes Consolidation Act 1997 section 82

Pre-trading expenditure

Section 82 provides relief for expenditure incurred in the three years before a trade or profession commences, allowing qualifying pre-trading costs to be treated as deductible expenses from the date the business starts.

• Expenditure incurred within three years before a trade or profession commences may be treated as if it were incurred on the first day of trading, provided the trade commenced on or after 22 January 1997.
• Only expenses that would have been allowable deductions under Case I or II of Schedule D had they been incurred after trading began can qualify — capital expenditure and non-deductible items such as entertainment costs are excluded.
• Losses arising from pre-trading expenditure cannot be set off against other income or used for group relief; they may only be carried forward against future profits of the same trade or profession.
• Relief for qualifying pre-trading expenditure is available only under this section and cannot be claimed under any other provision of the Tax Acts.