The claim dated back to 2015 and was partly allowed at the First Tier Tribunal (FTT) after HMRC argued the camping pods were ‘fixed structures’.

Acorn Venture is an outdoor activities company based in south Wales which organises adventure trips for children. Accommodation is provided in a series of camping pods, which Acorn said were moveable and therefore qualified for tax relief.

The company made a claim for annual investment allowance (AIA) for the period ending 30 September 2015 for AIAs of £354,489 for 26 camping pods which had been installed at the Royal Oak centre.

HMRC took seven years to respond fully to Acorn Ventures, issuing a final closure notice reducing the AIA claim by £285,997. This was split into two parts, one reduction of £272,140 for capital expenditure on the pods and £13,857 in legal fees.