As with many forms of tax relief, there are conditions that have to be met and technicalities to overcome before the benefit can be realised.

The new tax relief applies to both capital and revenue expenditure, so that it applies not only to property investors but also to commercial developers including house builders. The legislation is very broad in its scope and will apply to a wide range of construction projects. The relief has been set at 150% to encourage take up but it would still be surprising if the Inland Revenue do not subject claims to close scrutiny.

A number of the terms used lack precise definition and as the legislation is new it has yet to be tested before the Courts. However, based on our experience with capital allowances and the CTSA regime, it is possible to anticipate some of the obstacles and take steps to get around them.