Readers’ forum: Allowances claimant

I have recently taken on a new client. The circumstances are that the client has a conventional group structure namely a holding company with a wholly-owned trading subsidiary. The holding company which owns the newly acquired trading premises has granted a lease to the trading subsidiary for occupation of the premises. The premises building is very old. Substantial sums have been spent by the trading subsidiary in renovating the building to make it fit for the purpose of its trade.

My query relates not to integral features but to the structures and buildings allowance (SBA). According to the HMRC guidance SBAs are claimed by the person who has the relevant interest in the building. The general principle appears to be that the relevant interest in relation to any qualifying expenditure is the interest in the building or structure to which the person who...