Entitlement to allowances
B3.1102 Business premises renovation—qualifying expenditure
The definition of qualifying expenditure is amended by FA 2014 in relation to expenditure incurred on or after 1 April 2014 (corporation tax) or 6 April 2014 (income tax)1.
Old rules pre FA 2014
Qualifying expenditure is defined as capital expenditure incurred on or in connection with the conversion or renovation of a 'qualifying building' (see B3.1103) into 'qualifying business premises' (see B3.1104), or on capital repairs incidental to such conversion or renovation2. This appears to exclude repair expenditure on a non-qualifying building that is incidental to repairs to a qualifying building.
Expenditure is not qualifying expenditure if it is incurred on or in connection with3:
(a) the acquisition of land or rights in or over land, accordingly the acquisition costs of the qualifying building itself, or a leasehold interest in it, are excluded
(b) the extension of a qualifying building, except to the extent required for the purpose of providing a means of getting to or from qualifying business premises
(c) the development of land adjoining or adjacent to a qualifying building; or
(d) the provision of plant and machinery, other than plant or machinery which is or becomes a fixture as defined by CAA 2001, s 173(1) (see B3.355)
Capital expenditure on repairs is any expenditure that would not be allowed as a deduction in calculating the profits of a property business, or of a trade, profession or vocation, for tax purposes4.
In London Luton Hotel BPRA Property Fund LLP v Revenue
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