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Capital or revenue expenditure?

By Kevin Read, November 2020

Kevin Read reviews recent case law on re-surfacing land. 

Whether re-surfacing work is allowable revenue expenditure or extra capital expenditure on the land will depend on whether it can be seen to enhance the working area or value of the site. 

Resurfaced yard  

The recent case Steadfast Manufacturing & Storage v Revenue and Customs [2020] UKFTT 286 (TC) concerned an appellant that leased a factory and yard. The latter had not been resurfaced since before the site was acquired and was in poor condition. Some areas were unstable and unsuitable for use by forklift trucks, although they were used when necessary to turn the trailers for articulated lorries.  

Historically, the yard was repaired twice a year by patching with gravel. The forklift trucks would quickly damage this material and, with this patching becoming

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