Questione giuridica chiave
Whether the costs for the modernization of property A were deductible maintenance expenses or non-deductible value-adding/new-build costs.
Decisione estratta
The works amounted to a complete replacement of the stall section and thus to a new creation of value; the costs were not deductible as maintenance.
Motivazione estratta
Modernization can qualify as maintenance only if it restores former comfort. Here, objective technical features showed that walls, floor, ceiling, interior fittings and the manure system had to be replaced, so the work was effectively a new stall construction.