Ask an expert: Reclassifying claims for industrial building allowances

Question

My client (a married couple) bought a derelict manor house in early 2004 and spent around £1.8m converting it into a boutique hotel and spa completing the project in March 2005. As the property was a qualifying hotel for the purposes of CAA 2001 s 279 the client made a claim for industrial building allowances (IBAs) for the tax year ending 5 April 2005 on the entire cost of the conversion works that was agreed with HMRC. With the removal of IBAs is there any scope for them to reclassify any element of the claim that represented expenditure of qualifying fixtures and now claim this as plant & machinery allowances?

Answer

It has always been the case that expenditure...