Revenue expenditure and software royalty principles protect operational marketing costs and cloud-service subscriptions from disallowance.

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....Marketing and advertising expenditure incurred to promote an already operational online streaming platform is described as revenue expenditure where it supports business expansion and user engagement without creating a new capital asset or advantage in the capital field. The notes state that the enduring-benefit test is not conclusive and that such expenditure cannot be treated as preliminary expenditure for amortisation. They also state that end-user payments to non-residents for subscription-based software and cloud services are not royalty absent a right to exploit underlying copyright or intellectual property; accordingly, no tax deduction at source obligation arises and related disallowance is not warranted.....