Article 82 requires the apportionment of capital expenditure for assets that serve both business and private/non-taxable purposes. If a capital asset is used only partly for the business, the amount of expenditure eligible for depreciation is strictly limited to the portion corresponding to its business use. This ensures that taxpayers cannot claim a full tax deduction for the capital cost of assets (such as vehicles or properties) that provide personal benefits or relate to non-taxable activities, maintaining a fair and accurate link between deductible investment and the production of taxable gross income.
Part 3 - Chargeability to Tax
Chapter 3 - Depreciation of Capital Assets
Section 2 - Determination of Capital Assets and Expenses Related Thereto
Article 82
[GTL Notes: Apportionment of Capital Expenditure for Partial Business Use]
If a capital asset is used partly for the purposes of carrying on the business, the amount of expenditure incurred for acquiring that asset shall be limited to the amount corresponding to that part used for carrying on the business.
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