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Is replacing a roof revenue expenditure?

Question:

I have a post-war (1945) semi-detached property. The roof tiles are now brittle and loose, with water penetration at various places across the roof. When viewed from within the loft space, daylight is clearly obvious. There is also evidence that the roof timbers have wet rot and require replacing. The roof is original and now is some 80 years old, and it appears unfit for purpose (keeping the house watertight). Because there is no felt to support the water tightness, the roof needs to be replaced and, in part, repaired (joists, etc). Could this be considered as in-year maintenance, allowing the property to be rented out with a roof fit for purpose? 

Arthur Weller replies:  

If you look at HMRC’s Business Income Manual at BIM35400, from page BIM35430 onwards, you can see HMRC's discussion about this. You can see something more to the point on BIM35467. There were two court cases on this matter, Bullcroft and Samuel Jones. One of them was decided to be capital expenditure, and one was decided to be revenue expenditure. If you claim revenue expenditure for the replacement of your roof, you will have the case of Samuel Jones to rely on, so it is worth doing so. However, the cost is likely to be a lot, so HMRC may notice it and question you, and you will have to justify yourself. 

I have a post-war (1945) semi-detached property. The roof tiles are now brittle and loose, with water penetration at various places across the roof. When viewed from within the loft space, daylight is clearly obvious. There is also evidence that

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This question was first printed in Property Tax Insider in September 2024.