This applies in America as well, at least for the IRS. One can only run a money-losing business for a few years before they stop considering you a business and instead a hobbyist.
I think part of the equation is whether you are earning and spending money designed to eventually make money (supposedly), or whether you have a consulting business with nearly zero revenue and (say) $5000/year in expenses, ie, you have a fake consulting company with one employee, yourself, so you can deduct your hobby expenses.
If you have 10 people working for you, customers paying you every month, a loan for a building or equipment, etc., my guess is that the IRS will let your business run at a loss much longer.
