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Part 2U.K.Trading income

Chapter 5U.K.Trade profits: rules allowing deductions

Expenses connected with foreign tradesU.K.

93Allocation of expensesU.K.

(1)Expenses within section 92(3)(a), (b) or (c) are allocated to the foreign trade.

(2)If—

(a)the expenses are within section 92(3)(a) or (b), and

(b)the trader carries on more than one foreign trade at the place in question outside the United Kingdom,

those expenses are allocated between the foreign trades on a just and reasonable basis.

(3)If—

(a)the expenses are within section 92(3)(c), and

(b)the trader's absence is for the purpose of carrying on more than one foreign trade,

those expenses are allocated between the foreign trades on a just and reasonable basis.

(4)Expenses within section 92(3)(d) are allocated—

(a)to the trade carried on at the trader's place of destination, if that trade is a foreign trade, and

(b)in any other case, to the foreign trade carried on at the trader's place of departure.

(5)If the trader carries on more than one foreign trade at—

(a)the place of destination (in a case falling within subsection (4)(a)), or

(b)the place of departure (in a case falling within subsection (4)(b)),

the expenses are allocated between the foreign trades on a just and reasonable basis.