Motor dealer group, FRF (South Wales) Ltd, has won an appeal at the First Tier Tribunal (FTT) related to a claim for business premises renovation allowance (BPRA) for the conversion of an empty warehouse into a Toyota showroom.

The renovation cost FRF Motors £1.675m back in 2016 and it put in a claim for £280,000 in tax relief on £1.39m of the overall charge.

HMRC argued that the expenditure was not all used on the renovation or conversion of the warehouse, issuing a closure notice on 15 June 2021 for FRF’s tax return dated 31 December 2016.

The tribunal had to rule on the statutory meaning of the words ‘conversion’ and ‘renovation’ in this context, and whether the works carried out fitted with these descriptions. Judge Nigel Popplewell said: ‘If so, the appellant succeeds. If not, HMRC succeed.’

Another c