HMRC internal manual

Business Income Manual

Farming: cost of reclaiming scrubland formerly under cultivation

S33 Income Tax (Trading and Other Income) Act 2005, S53 Corporation Tax Act 2009

Where land which was under cultivation within a reasonable period in the past has been allowed to relapse into a wild state, the net expenditure incurred on clearing it for cultivation may normally be treated as revenue expenditure in computing profits for taxation purposes. However, where the present owner is known to have acquired the land at a depressed price because of its uncultivated condition, the capital element of the expenditure should be disallowed (see BIM46900 onwards).