A limited liability partnership was not entitled to business property renovation allowances on the full amount claimed in respect of expenditure incurred in the conversion of a former flight training centre into a Ramada Encore hotel. 

Summary 

A limited liability partnership (LLP) was not entitled to business property renovation allowances (BPRA) on the full amount claimed in respect of expenditure incurred in the conversion of a former flight training centre into a Ramada Encore hotel. 

Background 

The appellant limited liability partnership converted a former flight training centre it owned near London Luton Airport into a hotel. It claimed capital allowances under the BPRA capital allowances provisions of £12,748,201 in its tax return for 2010/11 as capital expenditure ‘on, or in connection with’ the conversion works (within CAA 2001, s 360B(1)(a)). HM