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HMRC internal manual

Business Income Manual

Historic houses: expenses allowable

Where the opening of the house to the public is a trade, the occupier is entitled to claim as a deduction so much of any revenue expenditure which is incurred on the upkeep of the house, its contents and the gardens as is referable to the trading activity. If the occupier continues to use the house as a residence, there will normally be three kinds of expenditure, namely:

  1. expenses wholly chargeable against the trade,
  2. expenses wholly referable to domestic or private purposes,
  3. common expenses which fall to be apportioned, on the basis of the facts of each case, between the specific trading activities and the general use of the house etc as a residence. These expenses would, for the most part, continue irrespective of the public showing, and during periods in which the house is not actually occupied although it is available as a residence. The normal approach in the case of such expenses should be to seek to agree the part which is proper to the trading activities rather than merely to disallow a proportion to cover the private use.