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Cairnsmill Caravan Park v HMRC

In Cairnsmill Caravan Park v HMRC (TC02580 – 15 March) a partnership operated a caravan park. It claimed a deduction for the cost of resurfacing part of the park replacing the previous grass surface with a hardcore surface. HMRC rejected the claim on the basis that the expenditure was capital. The First-tier Tribunal allowed the partnership’s appeal. Judge Reid held that the work had not resulted in any improvement to the park observing that the new surface had less aesthetic appeal was not suitable as a recreational area for children and had generated customer complaints. He held that the expenditure should be treated as revenue rather than capital.

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Why it matters: The First-tier Tribunal accepted the partnership’s contention that the cost of resurfacing part of the caravan park was an allowable deduction and rejected HMRC’s view that it should...

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