Residential rental – UPVC windows

Residential rental – UPVC windows

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Replacing wooden windows that are not broken or falling apart is clearly a capital expenditure.

However the wooden windows would have needed painting at about the same time as they were replaced to prevent them starting to rot, so the cost of painting would have come under “prevent the property from deteriorating”.

So can the cost of the saved painting be offset against revenue while the rest of the costs of the UPVC windows are offset against capital?

Ian Ringrise

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Euan's picture
By Euan MacLennan
09th Jun 2009 12:46

Stephen
I think that "necessarily" is implicit in the term "repair" for it to avoid being regarded as an improvement which is defined as capital expenditure and hence, is not deductible as a revenue expense.

In the judgement quoted under the last heading "Repairs to let property" in PIM2020, Buckley LJ said:

"... the test is whether the act to be done is one which in substance is the renewal or replacement of defective parts ..."

Ian's windows are not defective parts - they just require some routine maintenance. Replacing perfectly good working windows with double-glazed units is an improvement and therefore, capital expenditure. The Revenue's view is that they will accept double-glazed replacements instead of genuine repairs - they are not giving carte blanche to improve the property by upgrading the windows.

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By User deleted
09th Jun 2009 15:24

Information
I said 'Particularly if it replaces SG units' the OP has not yet confirmed the type of windows in question. Regards Peter

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By stephenkendrew
09th Jun 2009 12:03

Euan
I agree that the strictly correct answer to Ian's question is indeed no.

However, isn't your last paragraph effectively adding "necessarily" to the test of what is and is not allowable.

Almost the last sentence of your link says that HMRC "now accept that replacing single-glazed windows by double-glazed equivalents counts as allowable expenditure on repairs." There is no mention of whether the windows needed replacing or not.

As far as Ian is concerned, I think he can claim the full cost as a revenue expense.

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Euan's picture
By Euan MacLennan
09th Jun 2009 11:07

Not so sure
I agree that the replacement of rotten wooden windows with modern UPVC double-glazed windows is acceptable as a revenue expense, but this is not what Ian asked.

As it says in PIM2020, ESC B4, which allowed "notional" repairs (the cost of the repainting) to be deducted from revenue when there was a capital improvement was withdrawn from April 2001, so the answer to Ian's specific question is No.

In Ian's case, his windows are not rotten or broken, they do not need fixing - they are just due to be repainted. You might well get away with claiming the cost of the UPVC replacement windows as a a revenue expense, but if challenged by HMRC, you would need to justify the cost by demonstrating that the windows needed to be replaced, not just given a much cheaper lick of paint.

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By stephenkendrew
09th Jun 2009 10:08

Time flies!
Pete's correct, apart from the year.

Look at Tax Bulletin 59 (issued in June 2002): -

http://www.hmrc.gov.uk/bulletins/tb59.htm#c

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By User deleted
08th Jun 2009 18:57

Change of Practice
HMRC relaxed the rules back in 2007. UPVC DG can be set against revenue. Particularly if it replaces SG units. Regards Peter

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By jillian_g
01st Mar 2011 10:56

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