ITO Section 67

Apportionment of deductions.

(1) Subject to this Ordinance, where an expenditure [“expenditures, deductions and allowances”] relates to –

• (a) the derivation of more than one head of income; or 
• [(ab) derivation of income comprising of taxable income and any class of income to which sub-sections (4) and (5) of section 4 apply, or;]
• (b) the derivation of income chargeable to tax under a head of income and to some other purpose, the expenditure  [“expenditures, deductions and allowances”] shall be apportioned on any reasonable basis taking account of the relative nature and size of the activities to which the amount relates.

(2) The  [Board] may make rules under section  [237] for the purposes of apportioning deductions  [expenditures and allowances].