IHTM28012 - Liabilities: restricted deductions: meaning of 鈥榤aintain鈥� and 鈥榚nhance鈥�
皇冠体育app words 鈥榤aintain鈥� and 鈥榚nhance鈥� extend the scope of the provisions beyond simply buying either excluded property (IHTM28014) or assets that qualify for relief (IHTM28019).听
Both words have their normal meaning. 鈥楳aintain鈥� means to keep in good or proper order, and 鈥榚nhance鈥� means to improve or augment. 皇冠体育appse words are most likely to apply in connection with borrowing money to maintain听or enhance buildings.听
Where a person borrows money instead of using their own money to acquire听assets, it could be said that they have 鈥榤aintained鈥� the value of their other assets. So听if they were not domiciled in the UK听(to 5 April 2025)听(IHTM13000)听or not听a听long-term resident (from 6 April 2025)听(IHTM47000)听and听held most of their assets abroad, borrowing against UK assets could be said to be 鈥榤aintaining鈥� the value of excluded property. Individuals are free to choose how to use and invest their assets and whether to borrow money. So听you should not normally disallow the deduction of a liability in these circumstances.听
But,听any case where the borrowing against UK assets appears to be part of arrangements that are primarily designed to avoid these provisions and obtain a tax advantage should be referred to Technical.