Definition§
The duality principle in UK taxation law specifies that expenditure is non-deductible in the computation of profits subject to tax if it has a dual purpose (i.e., serving both business and personal or other non-business purposes). In such cases, a deduction for trading profits is only allowable if the expenditure is incurred wholly and exclusively for the trade. Relief may be permitted when a dissection of the payment allows identification of a solely business-related expense.
Key Characteristics§
- Business Purpose: Expenses must be incurred wholly and exclusively for business purposes.
- Duality: Expenditures serving both business and non-business purposes are typically non-deductible.
- Dissection: Relief can be claimed if business-related expenses can be independently identified within a dual-purpose transaction.
Examples§
- Travel Expenses: If a business trip also includes personal vacation time, only the expenses strictly related to the business part of the trip may be deductible.
- Meal Expenses: A meal with a client may be partly business (discussing deals) and partly personal (socializing), but only costs directly related to the business discussion might be deductible.
- Vehicle Use: If a company car is used for both personal and business purposes, only expenses strictly correlated to its business use are deductible.
Frequently Asked Questions (FAQs)§
What does ‘wholly and exclusively’ mean in terms of deductible expenses?§
‘Wholly and exclusively’ means that the expenses must be incurred solely for the purpose of the business, with no element of personal gain or benefit.
Can I claim a deduction if personal benefits from an expense are minimal?§
No. The duality principle stipulates that the entirety of the expense must serve the business purpose fully and independently to be deductible.
What happens if an expense cannot be clearly divided into business and personal segments?§
If an expense cannot be clearly divided, it is usually considered non-deductible due to its dual-purpose nature.
Can apportionment be considered for duality?§
No. Relief by apportionment is generally not permissible under the duality principle. The expense should be dissectable to identify wholly business-related costs.
Are there any exceptions to the duality principle?§
Exceptions are rare and specific. Generally, identified business expenses within a dual-purpose outlay must stand alone to qualify for deductions.
Related Terms§
- Allowable and Disallowable Expenses: Expenses that are either permissible or not permissible as deductions in the calculation of taxable profits.
- Trading Profits: Profits arising from the regular activities of a trade or business.
- Capital Allowances: Deductions permitted for certain capital expenditures related to business assets.
Online References§
Suggested Books for Further Studies§
- “Taxation: Incorporating the 2023 Finance Act” by Melville A.
- “UK Taxation: A Simplified Guide” by Satheesh Chandran.
Accounting Basics: “Duality Principle” Fundamentals Quiz§
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