Commentary on Sections Overview Chapter 3: Trade profits: basic rules Section 51: Relationship between rules prohibiting and allowing deductions
212.This section makes clear the interaction between those provisions that allow a deduction and those provisions that prohibit a deduction. It is new. See Change 7 in Annex 1. The corresponding rule for income tax is in section 31 of ICTA.
213.The general principle is that a rule allowing a deduction takes priority over a rule prohibiting a deduction. But this is subject to a number of exceptions.