Expenditure which is incurred wholly and exclusively for the purposes of a Taxable Person’s Business which is not capital in nature is deductible.
For a Tax Group, the assessment of whether expenditure meets this criterion should be based on the entire Tax Group. Consequently, expenditure incurred for the business of another member of the Tax Group (or multiple members) may be deductible. However, expenditure related to a non-Tax Group member’s business, such as a foreign parent that is not a Resident Person, is not deductible.