What was happening with BP. Bp were paying service station lump sum payment to get rid of the other oil suppliers that were on their premises. Back in the day when you go into the service station there would be diff pump there from various oil companies. You pul up to a pump , all be the same price no competition therefore. You pull into a service station and buy your petrol from whichever was available. The large companies were paying the service station owners to only sell the one product. At the time bp was smaller oil companies.. At the time the case came around they have been asked to get rid of quite a few station in aussie. They were in a position where they had to catch up and had to pay the petrol station owner to have these exclusive arrangement for them. They tried to they claim as deduction, BP are paying these amount to the service station owner. So they want to them to be deductible. Want to be able to claim these as a deduction. It went through to the privy council the highest court. They looked at the question to whether the amounts paid were capital or rev? One factors that comes up is time. On average these agreement lasted about 3-5 years on average. The sum of money were called a development allowance but service station could ? spend the money however they like. They didn't have to spend on capital improvement or anything operational. shrotne