Allowable Expenditure PDF

GBC0019 PERSONAL INCOME TAX DEDUCTIBLE EXPENSES Introduction ▪ Consideration on items constitute gross income ▪ Necessary to also consider the deduction that can be made from the gross income to arrive at adjusted income Steps in ascertaining Chargeable income Ascertain basis...

GBC0019 PERSONAL INCOME TAX DEDUCTIBLE EXPENSES Introduction ▪ Consideration on items constitute gross income ▪ Necessary to also consider the deduction that can be made from the gross income to arrive at adjusted income Steps in ascertaining Chargeable income Ascertain basis period for each source (S.20 & S. 21) Ascertain gross income from each source for the basis period S.22 & S. 32 Compute statutory income from each source S. 42 Compute aggregate income S. 43 Compute total income S. 44 Compute chargeable income (S. 45 & S. 51) Steps in ascertaining Chargeable income Ascertain basis period for each source (S.20 & S. 21) Ascertain gross income from each source for the basis period S.22 & S. 32 Compute adjusted income from each source and/or adjusted loss from business source S.33 to S.41 Compute statutory income from each source S. 42 Compute aggregate income S. 43 Compute total income S. 44 Compute chargeable income (S. 45 & S. 51) Sukaneka Sdn Bhd Tax Computation for the year of assessment 2021 RM'000 RM'000 s4(a) Business source Less Add Profit before taxation 1,409.33 Slow moving inventories written off 28 Depreciation 120 Interest income on fixed deposits 23 interest received on overdue trade debts 4 Bad debts written off 4.67 Tax filing fees NIL Tax fees- new business 5 foreign exchange loss 34 Interest expense 14 Salary paid to disabled staff 21 Equipment for disabled staff NIL 76 1,587 -76 Adjusted income 1,511 Steps in ascertaining Chargeable income Ascertain basis period for each source (S.20 & S. 21) Ascertain gross income from each source for the basis period S.22 & S. 32 Compute adjusted income from each source and/or adjusted loss from business source S.33 to S.41 Steps in ascertaining Chargeable income Ascertain basis period for each source (S.20 & S. 21) Ascertain gross income from each source for the basis period S.22 & S. 32 Compute adjusted income from each source and/or adjusted loss from business source S.33 to S.41 Compute statutory income from each source S. 42 Compute aggregate income S. 43 Compute total income S. 44 Compute chargeable income (S. 45 & S. 51) 6.1 Legislative Provisions S33 S39 S34 S35 general rule Expenditure Specific treatment of deductions to be specifically deductions trading stock. made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.2 Tests Applied for Granting Deductions 1 Is the expenditure of a revenue or capital nature? Is the expenditure in respect of the business activities carried on by the 2 taxpayer? 3 Is the expenditure authorised or prohibited by any provision of the Act? 4 Is the expenditure incurred in the relevant year? 5 Is the expenditure wholly and exclusively incurred in the production of gross income? Deductible Expenses : General Framework 6.3 Capital and Revenue Expenditure ▪ Immaterial considerations: a. A lump sum payment vs periodic payments. b. The reasonableness or magnitude of the expenditure. c. The character of a receipt. d. The payment of an amount out of capital funds? e. The accounting treatment of an item of expenditure? Due regard must be given to the facts of a case. 6.3 Capital and Revenue Expenditure 1. Once and For All” Test ▪ A recurring expense or a once and for all payment? ▪ Recurring expense --> revenue outlay ▪ Once and for all expense → capital outgoing in nature ▪ Vallombrosa Rubber CO. Ltd vs Farmer (5 TC 529) In a rough way … capital expenditure is a thing that going to be spent once and for all, and income expenditure is a thing that going to incur every year. 6.3 Capital and Revenue Expenditure..cont’ 2. Enduring Benefit” Test ▪ Expenditure incurred to acquire a business? ▪ A right of a permanent character? ▪ An asset which generates income? ▪ Preventing competition? ▪ Acquiring a source of income or a capital asset? ✓ Bringing into existence an asset or advantage for the enduring benefit 6.3 Capital and Revenue Expenditure…cont’ 3. “Identifiable Asset” Test Where it is shown that asset of a capital nature has been acquired. 4. Fixed Versus Circulating Capital ▪ If an expenditure relates to fixed assets? ▪ If the expenditure relates to circulating capital? ▪ Merely for the purpose of maintaining capital assets? ▪ If interest is paid on a loan obtained to acquire fixed assets? ✓ Expenditure may be capital for one business and revenue on the other 6.3 Capital and Revenue Expenditure…cont’ 5. “Business Entity” Test ▪ Distinction between business structure and business process: The acquisition of means of production and use of them? Establishing or expanding and carrying on the business? An enterprise itself and the sustained effort of those engaged in it? 6.1 Legislative Provisions S33 S39 S34 S35 general rule Expenditure Specific treatment of deductions to be specifically deductions trading stock. made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.1 Legislative Provisions S33 general rule deductions to be made from gross income. 6.4 The General Deduction Provision S33(1) ▪ The crucial elements: a. outgoings and expenses; b. wholly and exclusively; c. incurred; d. in the production of gross income. ▪ Allowed against the particular source. ▪ If a business is carried on by a Malaysian resident in a foreign country? ▪ The expenses incurred in generating exempt income? 6.4 Section 33(1) 1. Outgoings and Expenses ✓ “Outgoings” has a wider meaning than “expenses”. ✓ Outgoings include theft or defalcation by employees, specific bad debt etc. 2. Wholly and Exclusively ✓ “Wholly” refers to quantum of the expenditure. ✓ Deals with the principle of remoteness. ✓ “Exclusively” refers to motive behind the incurrence of expenditure. ✓ Deals with the principle of duality of purpose. 3. Incurred ✓ “Incurred” mean the right to receive. ✓ Include “paid”, “payable” or “becoming payable”. 6.4 The General Deduction Provision 5. In the Production of Gross Income ✓ The outlay was for the purpose of producing income. ✓ The cost of terminating business operations? ✓ Expenditure or loss made after the income-producing activities have ceased? ✓ Where the business has ceased temporarily? ✓ Expenditure incurred for the protection of income? ✓ Expenditure or loss made to reduce current or future expenses? 6.6 Deductible and Non-Deductible Expenses General Deductions [S. 33(1)] - Expenses wholly and exclusively incurred in the production of gross income: a. Interest; b. Rent; c. Repairs and renewals: ▪ The Entirety or Part of an Entirety; ▪ Improvement ▪ Initial Repairs d. other deductions which may be prescribed by the MOF. Interest example : Interest disallowable for tax purposes Interest Money Money Loaned or 150,000.00 Month End Jan x 1,000.00 = 500.00 Payable Borrowed Invested 300,000.00 300,000.00 Feb x 1,000.00 = 750.00 RM RM RM 400,000.00 Jan 1,000.00 300,000.00 150,000.00 Mar Money Invested > money borrowed, whole interest deductable 1,000.00 Feb 1,000.00 400,000.00 300,000.00 Money Invested > money borrowed, whole Apr interest deductable 1,000.00 Mar 1,000.00 250,000.00 300,000.00 500,000.00 Apr 1,000.00 150,000.00 300,000.00 May x 1,000.00 = 714.29 700,000.00 May 1,000.00 700,000.00 500,000.00 Jun Money Invested > money borrowed, whole interest deductable 1,000.00 Jun 1,000.00 400,000.00 500,000.00 200,000.00 Jul x 1,000.00 = 333.33 Jul 1,000.00 600,000.00 200,000.00 600,000.00 Money Invested > money borrowed, whole Aug 1,000.00 nil 200,000.00 Aug interest deductable 1,000.00 Sep 1,000.00 350,000.00 200,000.00 Sep 200,000.00 x 1,000.00 = 571.43 350,000.00 Oct 1,000.00 100,000.00 nil The whole interest will be Oct - Nov 1,000.00 700,000.00 300,000.00 allowed as there is no Dec 1,000.00 400,000.00 300,000.00 300,000.00 Nov x 1,000.00 = 428.57 700,000.00 Total 12,000.00 4,350,000.00 3,250,000.00 300,000.00 Dec x 1,000.00 = 750.00 400,000.00 8,047.62 6.6 Other Deductions (1) 1. Donations in Kind to National Disaster Relief Fund 2. Forest Premium and Pawnbroker’s Tender Fee 3. Pre-commencement Business Training Expenses 4. Information Technology-related Expenditure 5. Acquisition of Proprietary Rights 6. Promotion of Exports (2) 7. Promotion of Exports (3) 8. Cost of Developing a Website 9. Issuance of Islamic Securities 10. Preparation of Corporate Knowledge Based Master Plan 6.6 Other Deductions (2) 11. Investment in an approved consolidation of management of smallholding and idle land project 12. Payment of Legal and Consultancy Services 13. Cash Contribution and Sponsor of a Cultural or Arts Show 14. Investment in a Project of Commercialisation of Research and Development Findings 15. Audit Expenditure 16. the Development and Compliance of New Courses by Private Higher Education 17. Cost of Issuance of the Islamic Securities 18. Issuance of Islamic Securities Pursuant to Principles of Murabahah and Bai Bithaman Ajil 19. Expenditure for Establishment of an Islamic Stock Broking Business 20. Investment in a BioNexus Status Company 6.6 Other Deductions (3) 21. Cost of Spectrum Assignment 22. Cost of Obtaining Chain of Custody Certification from the Malaysian Timber Certification Council 23. Commencement of Business Expenses Relating to Employee Recruitment. 24. Benefit and Gift from Employer to Employee 25. Investment in an Approved Forest Plantation Project 26. Contribution to Retirement Fund 27. Payment of Premium to Malaysia Deposit Insurance Corporation 28. Investment in an Approved Food Production Project 29. Contribution to Universal Service Provision Fund 6.6 Other Deductions (4) 30. Deduction for Expenditure to Obtain The 1-InnoCERT Certification 31. Expenditure on Franchise Fees 32. Expenditure on issuance of Retail Debenture and Retail Sukuk 33. Relocation costs for Tun Razak Exchange Marquee Status Company 34. Pre Commencement Expenses in Relation to Refinery and Petrochemical 35. Cost of Acquisition of Foreign Owned Company. 36. Provision of Child Care Centre. 37. Expenditure in Relation to Minimum Wages 38. Cost Relating to Training for Employees for The Implementation of GST 39. Secretarial Fee and Tax Filing Fee 6.1 Legislative Provisions S33 S39 S34 S35 general rule Expenditure Specific treatment of deductions to be specifically deductions trading stock. made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.1 Legislative Provisions 6.1 Legislative Provisions S33 S39 general rule Expenditure deductions to be specifically made from gross disallowed income. 6.5 Lease Rentals [S. 39(1)(k)] ▪ The deductible expenses for rental of private motor vehicles is up to RM100,000 per vehicle subject to: the vehicle is new; and the total cost of the vehicle ≤ RM150,000. ▪ If these conditions are not fulfilled, a restriction of RM50,000 apply. ▪ Does not include vehicles licensed by the appropriate authority for commercial transportation e.g. lorry, truck, bus, mini bus, van, station wagon or taxi cab.  Lease Rentals : Example Prefab Enterprise Sdn Bhd is a manufacturing company with a 31 December accounting year end. It leased three cars for aperiod of three years for theuse of durectors and seniror executives. The cost of pruchase would exceed RM150000,. Dteails as pbelow : Type of Commenceme Monthly Cars nt Lease rental RM Volvo 1-Feb-15 2,000.00 BMW 1-Nov-15 3,000.00 Mercedes 1-May-15 3,500.00 How much is the lease rentals would be deductable for year ended 31 Dec 2017? Solution : Rentals Amount Amount not YA YE 31 Dec Type of Car Paid deductable deductable RM RM RM 2015 2015 Volvo 22,000.00 22,000.00 - BMW 6,000.00 6,000.00 - Mercedes 28,000.00 28,000.00 - 2016 2016 Volvo 24,000.00 24,000.00 - BMW 36,000.00 36,000.00 - Mercedes 42,000.00 42,000.00 - 2017 2017 Volvo 24,000.00 4,000.00 20,000.00 BMW 36,000.00 8,000.00 28,000.00 Mercedes 42,000.00 - 42,000.00 * The amount of rentals in respect of the cars is restricted to RM50,000 vehicle 6.5 Entertainment Expenses [S. 39(1)(l)] 1. Entertainment provided to employees 2. Entertainment business 3. Promotional gifts at foreign trade fairs 4. Promotional samples 5. Promotional gifts in Malaysia 6. Cultural or sporting events 6.5 Entertainment Expenses [S. 39(1)(l)]…cont’ 7. Wholly related to sales - excluding suppliers: a) Expenses on food and drink for launching of a new product. b) Redemption vouchers given for purchases made. c) Cash vouchers, discount vouchers, concert or movie tickets. d) Free gifts for purchases exceeding a certain amount. e) Redemption of gifts based on a scheme of accumulated points. f) Lucky draw prizes given to customers for purchases made. Example 1: Determine the deductibility of the following expenses: Twin Brothers Sdn Bhd provided a family day trip for its employees to Ilham Resot, Negeri Sembilan, to foster family values among its employees. The total cost incurred amounted to RM70,000 comprising cost of travel totaling RM40,000 and cost of food, drinks and accommodation totaling RM30,000. Since it is a family trip for the employees, it implies that the employer, employees and their immediate families participated in the trip, and the destination of the trip was in Malaysia (Terengganu), assuming that this is the only trip claimed by Twin Brothers, the RM40,000 for the cost of leave passage is deductible by virtue of proviso (viii) to paragraph 39(1)(l) of the ITA; and RM30,000 for the cost of food, drinks and accommodation provided to employees is deductible by virtue of proviso (i) to paragraph 39(1)(l) of the ITA Example 2 : Tanjong Auto Service carrying on a car servicing business provides light refreshments such as tea, coffee, sandwiches to its customers while waiting for their cars to be serviced. The customers are not charged for the light refreshments provided. The entertainment expense incurred on the light refreshments by Tanjong Auto Service is related wholly to sales arising from the business of Tanjong Auto Service, and the fact that it is provided when the customers are waiting for their cars implies that it is provided in the business owner’s premise, it is deductible under Proviso (vii). 6.1 Legislative Provisions S33 S39 S34 S35 general rule Expenditure Specific treatment of deductions to be specifically deductions trading stock. made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.1 Legislative Provisions 6.1 Legislative Provisions S33 S39 S34 general rule Expenditure Specific deductions to be specifically deductions made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.6.6 Specific Business Deductions (1) 1. Bad and Doubtful Debts 2. Employer’s Contribution to an Approved Scheme 3. Mining Allowance 4. Replanting Expenditure 5. Equipment for Disabled Employees 6. Translation/Publication of Books in the National Language 7. Library Facilities 8. Services, Public Amenities and Contributions to Specified Projects 9. Child Care Centre 10. Musical or Cultural Group 11. Sponsoring Arts, Cultural or Heritage Activity 6.6.6 Specific Business Deductions (2) 12. Scholarships 13. Certification Expenditure 14. Practical Training 15. International Standardisation Activities 16. Scientific Research Expenditure 17. Special Deduction for Scientific Research Expenditure 18. Contributions/Payments to an Approved Research Institute or an Approved Research Company 19. Expenses in Respect of Discount or Premium Incurred on the Subscription or Issuance of a Bond 20. Expenditure on Treasury Shares 21. Qualifying Pre-operational Business Expenditure 22. Business Zakat [2.5% of aggregate income] Bad and Doubtful Debts : example 1 The adjustments as follows: RM RM Profit and Loss Charge 80,000.00 Recoveries (Taxable) 20,000.00 Increase in Specific Provision 15,000.00 Bad debts write off (trade debt only) (RM65,000-RM10,000) 55,000.00 100,000.00 70,000.00 70,000.00 Add 30,000.00 RM30,000 should be add back in the tax computation, hence the actual deduction in respect of bad and doubtful debts : RM Recoveries (20,000.00) Increase in Specific Provision 15,000.00 Bad debts write off (trade debt only) (RM65,000-RM10,000) 55,000.00 50,000.00 *Since the charge in Profit and Loss is RM80,000, an amount of Rm30,000 is added back in the tax computation. * The loan to ex-employee is not a trade debt Bad and Doubtful Debts : example 2 Solarmax Sdn Bhd is a manufacturing company. For 31 Sept 2017, an amount of Rm52,000 was charge to the P&L is respect of "bad and doubtful trade debts". This was made up of : RM General provision created in the year 45,000.00 Bad debts write off 7,000.00 52,000.00 In addition, the general provision amounting to Rm22,000 was transferred during the year to specific provision since the debtor concern was place in liquidation. Further , an amount of Rm5,000 was placed on another debtor was written off against general provision. State the adjustments that can be made in respect of the above scenario in preparing tax computation of the company for YA 2017.  RM RM + - Profit and Loss Charge 52,000.00 Bad debts write off ( to P&L account) 7,000.00 Bad debts write off ( againts general provision) 5,000.00 Specific provision created (debtor in liquidation) 22,000.00 52,000.00 34,000.00 34,000.00 Add 18,000.00 RM18,000 should be add back in the tax computation, hence the actual deduction is only RM34,000 6.6 Other Types of Expenses (1) 1. Pre-commencement Expenses 2. Annual General Meeting, Printing of Accounts and Management Expenses 3. Fines and Penalties 4. Damages 5. Taxation 6. Maintenance of Existing Assets 7. Legal Expenses, Commitment and Guarantee Fees [e.g. 6.7] 8. Travelling Expenses/Leave Passage 9. Removal Expenses 6.6 Other Types of Expenses (2) 10. Subscriptions and Political Expenditure 11. Retirement of Unsatisfactory Director or Employee 12. Termination of Agency 13. Restrictive Covenants 14. Compensation for Loss of Office 15. Franchise Fees 16. Losses 17. Foreign Currency Losses (Exchange Fluctuations) 18. Expenditure Incurred During Temporary Cessation of the Business and After Cessation of the Business Question : Sky High Development Sdn Bhd., a company formed to develop Menara Sky-high at total construction cost of RM60 million, did not have necessary fund to finance the project. In 2017, it entered into a syndicated loan package agreement to obtain financing. Under the loan package, it was granted a bridging loan facility, by consortium of financial institution. The bridging loan is repayable within 3 years of initial drawdown. Apart from interest payment, other terms and conditions are : Commitment fee of ½ percent p/a to the lenders principal amount not drawdown as at December each year. Guarantee fee = 1% based on the amount outstanding loan as the beginning of each calendar year t the guarantor of the loan Shy High Sdn incurred Rm100,0000 commitment fee RM200,000 guarantee dee 2017. State whether the commitment fee is deductible or not Answer : Attention must be concentrated on the type of business which company involve in. The fact that the developer, it would such a normal case to have financing agreements. The commitment fees : paid to the lender is the revenue expenditure and it is allowable expenses as it is wholly and exclusively incurred to produce income. It is a payment for the use of loan the eventually utilized. It is payment to preserve the right to drawdown the amount of the loan. The guarantee fee : is a business expense in the borrowing of money very often necessitates the gibing of the guarantee by a third party so that if the borrower default the lender is assured the repayment of the loan up to the guarantee provided. the interest is allowable expenses, should be deductible since both the payment are similar. recurring payment and is for the use for the security provided by the guarantor. Further, the loan was taken for the construction of a building which is trading stock of the company. 6.8 Double Deductions (2) 14. Promotion of International/Private Schools 15. Participation in an Approved Career Fair 16. Structured Internship Programme 17. Scholarships 18. Child Care Centres 19. Interest and Incidental Cost in Acquiring Loan for Abandoned Projects 20. Payments made to Malaysian Motor Insurance Pool 21. Agrosukuk, Retail Sukuk and Retail Bonds 22. 1Malaysia Training Scheme Programme 23. Vendor Development Programme (VDP) 24. Flexible Work Arrangements (FWA) 25. Implementation of GST System 6.1 Legislative Provisions S33 S39 S34 S35 general rule Expenditure Specific treatment of deductions to be specifically deductions trading stock. made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.1 Legislative Provisions 6.1 Legislative Provisions S33 S39 S34 S35 general rule Expenditure Specific treatment of deductions to be specifically deductions trading stock. made from gross disallowed S34A : revenue income. expenditure. S34B : double deduction in respect of cash contributions. S34C : deduction of expenses on discount or premium. S34D : expenditure on treasury shares. 6.7 Stock in Trade ▪ Stock in trade include all raw materials, WIP and finished goods. ▪ Value of his trading stock a in ascertaining adjusted income: i. If value of stock at the end of the period > beginning of the period, the adjusted income will be increased by the amount of the excess; ii. If the value of the stock at the beginning of the period > end of the period, the adjusted income will be reduced by the amount of the excess. ▪ PR No. 4/2006: Importance of valuation of stock in trade and work-in-progress; Bases of valuation of stock in trade and work in progress; Special rules on cessation of business. Valuation of stock on cessation of operation 6.8 Double Deductions (1) 1. Halal Certification, Quality Systems and Standards Certification 2. Research Expenditure 3. Approved Research Institute/Company 4. Interest Payable on Loans to Small Businesses 5. Remuneration Paid to Disabled Persons. 6. Insurance Premiums on Import of Cargo 7. Export Credit Insurance Premiums 8. Insurance Premiums on Export of Cargo 9. Freight Charges 10. Participation in Approved International Trade Fairs 11. Overseas Expenses for Promotion of Tourism 12. Training 13. Advertising Expenditure on Malaysian Brand Name Goods Example Tranquility, an Orphanage home, incurred the following expenditure for the year ended 31 December 2019: RM Rental of premises 60,000 Purchase of chairs and tables 4,500 Foodstuff, writing materials and other supplies 27,000 Salary to the sole proprietor of Sentosa 36,000 Utilities, maintenance and upkeep of premises 16,300 Training of helpers and assistants 3,800 Advertisements and marketing 4,730 Required Briefly explain whether each item of expenditure is or is not deductible in arriving at the adjusted income of the nursing home for the year of assessment 2019.  Transaction Deductibility Reason Rental of premises Deductible Revenue expense incurred in the normal course of the business deductible under s.33(1)(b). Purchase of tables Not deductible Capital in nature as these are fixed assets and chairs Foodstuff, writing Revenue expense incurred in the normal course of the Deductible materials and other business. supplies Any payment to the proprietor represents profit from Salary to sole Not the business, therefore not tax deductible in arriving proprietor deductible at adjusted income.  Transaction Deductibility Reason Utilities, Revenue expenses incurred in the normal course of the maintenance and Deductible business. upkeep of premises Deductible Revenue expenses incurred in the normal course of the Training of helpers business. and assistants Advertisements and Deductible Revenue expenses to promote business marketing Questions? What is the main consideration in determining if an expense is deductible? Reasonableness of the expenditure Wholly and exclusively incurred in the production of gross income Magnitude of the expenditure Accounting treatment Which test is used to determine if an expenditure provides an enduring benefit? Identifiable Asset test Business Entity test Enduring Benefit test Once and For All test Which test distinguishes between business structure and business process? Enduring Benefit test Identifiable Asset test Business Entity test Once and For All test What is the distinction between the 'Once and For All' test and the 'Enduring Benefit' test? Source of income Duration of benefit Nature of expenditure Frequency of payment What type of expenses are considered non-deductible under Section 33(1)? Expenses incurred in the production of gross income Personal expenses Expenses incurred for business activities Entertainment expenses What type of expenses are deductible under Section 33(1)? Expenses incurred for non-business activities Expenses incurred in the production of gross income Expenses incurred for entertainment purposes Personal expenses What is the key element required for an expense to be deductible under Section 33(1)? Partially incurred Incurred in the production of gross income Incurred for non-business activities Incurred for personal use Which test is used to determine if an asset of a capital nature has been acquired? Business Entity test Identifiable Asset test Once and For All test Enduring Benefit test Which legislative provision allows for deductions against specific sources of income? Section 33(2) Section 33(3) Section 33(4) Section 33(1) Which test is used to determine if an expenditure is of a revenue or capital nature? Once and For All test Enduring Benefit test Identifiable Asset test Business Entity test