In response to a query as to whether a payment made for the transfer of brokerage clients in respect of whom trailer commissions were being received would be a deductible payment, CRA stated:
Costs incurred for the creation or the expansion of a commercial structure are considered to be on capital account as this type of expenditure gives rise to an asset of an enduring nature. A capital outlay to acquire a customer list for use in a business of a taxpayer in most cases qualifies as an eligible capital expenditure.