Capital allowances and the fixed value requirement

Steven Bone

Question

Over the last 20 years my client has built up a portfolio of commercial properties for investment purposes. He continues to buy properties regularly and has always claimed any capital allowances available using specialist advisers. But he has recently for the first time had a claim rejected on the basis that he had not satisfied the ‘fixed value requirement’ of CAA 2001 s 187A. This seems somewhat harsh as he clearly meets all other conditions. Can anything be done to get the claim accepted?

Answer

Your client appears to have fallen foul of rules introduced for property transactions from April 2012. On top of the existing capital allowances rules these imposed what HMRC initially described as ‘administrative requirements’.

Arguably the changes are more than just administrative ones and fundamentally change established law and practice. The new rules sit...

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