Amortisation of telecom spectrum and licence costs allows pro rata deduction over licence term with transfer adjustments.

Capital expenditure actually paid for acquiring rights to use spectrum or to operate telecommunication services is amortised in equal instalments starting in the tax year when business commences or the fee is paid, whichever is later, and continues for the period the spectrum or licence remains in force. Transfers of spectrum or licence require adjustment: shortfalls permit a one time deduction in the year of transfer; excess proceeds give rise to taxable business income to the extent of the excess up to the unallowed expenditure; and equal or greater proceeds prevent further deductions. Partial transfers reduce remaining unallowed expenditure and spread the remainder over unexpired years.

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