The London Hotel Luton BPRA Fund LLP case has been back and forth through the courts since 2016, with the latest decision falling in favour of HMRC as the First Tier Tribunal refused to reopen the case about apportionment of ‘residual amount’ relief, which has now come down to a disputed figure of £2,264,846.

This residual amount related to a disputed claim for £12.5m in business premises renovation allowance (BPRA) and whether HMRC had miscalculated the grounds for the claim by taking into account the original purchase price of the property.

The case hinged on various appeals which went right up to the Court of Appeal against HMRC’s decision to restrict the LLP’s claim for BPRA amounting to £12,478,201, related to the conversion of a flight training centre near London Luton Airport into a 124-room hotel.

HM