Under the Taxes Acts, expenditure which is wholly and exclusively laid out for the purposes of a trade is allowable as a deduction in arriving at profits which are subject to taxation. Unless a trade has commenced, no deductions can generally be claimed for pre-trading expenditure. There are however a number of reliefs which cater specifically for pre-trading expenditure, for example, relief for capital expenditure on scientific research; on construction of an industrial building; on the acquisition of patent rights and "knowhow"; in connection with a mine, and, for abortive exploration, expenditure on mining; on dredging; on the treatment of effluent; and on construction of toll roads and bridges. In addition, relief is available for certain pre-trading expenditure incurred on the recruitment and training of staff.
I am not aware of any recent representations seeking an alteration in the tax treatment of expenses in the start-up of businesses, or claiming that the establishing of new industry is hindered by the current tax treatment. I see no reason to change the present arrangements, especially given the current budgetary constraints.