In an email to the Heritage Group of Professional Advisers, of which some of our team are members, HMRC have confirmed that is it acceptable for owners of a national heritage property to close or delay opening it to later in 2020. Doing so will not mean that the owner has broken their agreement with HMRC, even if it means that the owner will miss some of the period covered by their agreement with HMRC, or they do not open at all in 2020.
If the situation improves HMRC expect the property to be open later in the year to make up for any lost days, if possible. HMRC do not expect additional open days next year to make up for those missed in 2020.
Similarly, if a conditionally exempted object is on loan to a museum, gallery or other venue which closes due to coronavirus, HMRC will not treat the withdrawal of public access to the object as if the owner had broken their agreement with HMRC. This will apply even if it means the object is not on show at all in 2020.
Finally, with regards to an object which can only be seen by appointment, HMRC do not expect the owner to agree to an appointment until the government’s advice changes, and in these circumstances, again, the owner will not have broken their agreement with HMRC.
