Telecom licence amortisation: phased tax deduction for licence acquisition and adjusted treatment on transfer.

Capital expenditure to acquire a telecommunication licence is deductible by annual amortisation using an appropriate fraction across the "relevant previous years" beginning when the fee is paid; on licence transfer, shortfalls of proceeds permit a deduction for remaining unallowed expenditure, excess proceeds may be taxed as business income, and full satisfaction of remaining expenditure ends future amortisation, with special carryover treatment in amalgamation transfers.

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