No. Identify the actual qualifying capital and transaction being assessed.
Avoid combining unrelated figures
Past spending, current commitment and other expenses may have different purposes. Review the real capital, risk and financing rather than using accumulated business spending as a universal threshold.
The funds irrevocably committed to acquiring and operating the enterprise: the purchase price actually paid, franchise transfer fees, inventory and equipment, and working capital placed at risk. Start by building the total cost the way a lender would: lease and deposits, kitchen equipment, leasehold improvements, licences, initial inventory, working capital for the first months. Substantiality is measured in proportion to the cost of acquiring the particular business, so a fully funded purchase of a modest operating business can qualify while a small fraction of an expensive one may not. The substantiality test compares the amount invested with the total cost of buying or establishing the enterprise, so a lower-priced business requires a higher proportion of the price to be invested. An acquisition front-loads the purchase price but may open with revenue; a startup spreads spending across fit-out, licensing and marketing while funding months of losses.