Enduring benefit test: ex-gratia payments under VRS treated as capital expenditure when they create lasting advantage. Ex-gratia payments made to effect Voluntary Retirement Schemes or similar restructuring that create an enduring benefit or advantage for the business - such as improved profitability, competitiveness or technological induction - are properly attributable to capital and not revenue. Assessing Officers should decide the character of such expenditure on the facts and circumstances of each case, considering the nature and ordinary course of the business and the objects for which the payments were made.