Martin Wilson

This Practice Note explains the rules on company reconstructions with respect to capital allowances for plant and machinery. It covers the transfer of a trade between UK companies without a change in ownership, the transfer of a trade between connected persons, a change of trade, and successions without a sale (including incorporations). This Practice Note was produced in partnership with Steven Bone.

This Practice Note is about the rules on capital allowances for taxpayers who are connected with one another. It sets out the meaning of connected, the capital allowances treatment of transfers of assets between connected persons, and the special rules affecting integral features, structures and buildings. This Practice Note was produced in partnership with Steven Bone.

This Practice Note describes the anti-avoidance provisions within the capital allowances rules. It covers transactions with a main purpose of obtaining a tax advantage, and capital allowance buying. Capital allowance buying involves selling or buying a company with the intention of using its unclaimed allowances. This Practice Note was produced in partnership with Steven Bone.

This Practice Note contains guidance on the practicalities of capital allowance related pre-contract enquiries on a property sale or acquisition. It provides assistance in understanding replies to pre-contract enquiries (CPSE.1) on this topic, and in knowing when to insist on further information. This Practice Note was produced in partnership with Steven Bone and Martin Wilson.

This Practice Note is about the interaction between the tax rules on capital allowances and those on capital gains tax and corporation tax on chargeable gains (CGT), VAT, stamp duty land tax (SDLT), land and buildings transaction tax (LBTT) and land transaction tax (LTT). It covers CGT computations, capital losses, the wasting asset rules, the impact of VAT and stamp taxes on the calculation of allowances, and the VAT capital goods scheme. This Practice Note was produced in partnership with Steven Bone.

This Practice Note is about the availability of capital allowances for plant and machinery where a person makes a contribution to another person’s expenditure. It covers the restrictions on allowances for recipients of contributions, and the allowances that are available to contributors. This Practice Note was produced in partnership with Steven Bone.

This Practice Note explains how capital allowances for plant and machinery are calculated for corporation tax purposes. It covers qualifying expenditure, pooling and writing-down allowances, the mechanics of claiming, or disclaiming, allowances, and the uses to which allowances may be put. It describes balancing charges and allowances, disposal events and disposal values, and time limits for making and amending claims. This Practice Note was produced in partnership with Steven Bone.

This Practice Note explains how capital allowances for plant and machinery are calculated for income tax purposes. It covers qualifying expenditure, pooling and writing-down allowances, the mechanics of claiming, or disclaiming, allowances, and the uses to which allowances may be put. It looks at the reasons a taxpayer might not want to claim allowances, and the restrictions on using trading losses generated by capital allowances. This Practice Note was produced in partnership with Steven Bone and Martin Wilson.

This Practice Note describes the meanings of the terms plant and machinery for the purposes of the tax rules on capital allowances. It covers the case law on the meaning of plant and the statutory limitations to the definition relating to buildings and structures, and the special rules on integral features. This Practice Note was produced in partnership with Martin Wilson.

This Practice Note explains the capital allowances rules for plant or machinery that is classified as a fixture, such as lifts, central heating equipment and boilers. It covers the meaning of a fixture, the special rules on who can claim allowances on fixtures, and how allowances on fixtures are calculated. This Practice Note was produced in partnership with Steven Bone and Martin Wilson.

This Practice Note explains the capital allowances rules for plant or machinery that is classified as an integral feature, such as electrical, cold water and heating systems. It covers the meaning of an integral feature, the tax treatment of repairs to integral features, and relevant anti avoidance rules. This Practice Note was produced in partnership with Steven Bone.

This Practice Note describes the types of expenditure that will qualify for capital allowances on plant and machinery, and the different rates at which relief is given. It provides guidance on the super-deduction, full expensing, the annual investment allowance, enhanced capital allowances, short-life assets, conventional plant and machinery allowances, integral features and long-life assets. This Practice Note was produced in partnership with Steven Bone.

This Practice Note is about elections under section 198 or 199 CAA 2001, which are relevant to capital allowances claims on fixtures that change hands as part of a real estate transaction (a property sale or the grant of a new lease). It provides guidance on the legal requirements for making an election, and lists common pitfalls that may make an election invalid. This Practice Note was produced in partnership with Steven Bone.

This Practice Note is about the capital allowances for expenditure on non-residential structures and buildings. This Practice Note was produced in partnership with Steven Bone.

This Practice Note provides a brief explanation of the tax rules on capital allowances, then more detail on what is meant by capital expenditure in this context. It covers the enduring benefit test, replacement assets, like-for-like expenditure, nearest modern equivalent, the Law Shipping principle and the special rules for integral features. This Practice Note was produced in partnership with Steven Bone.

This Precedent clause is for an agreement for lease where a landlord is making a capital contribution to the tenant (for instance a contribution towards the tenant’s fitting-out works) and wishes to claim capital allowances in respect of some or all of the contribution. This Precedent was produced in partnership with Steven Bone.

These precedent capital allowances clauses are for inclusion in a property sale contract. The clauses can be adapted where the transaction is the grant of a lease for a premium, or an asset purchase agreement in which real estate is being transferred as part of a wider sale of a business. This Precedent was produced in partnership with Steven Bone and Martin Wilson.

This Precedent section 199 CAA 2001 election is for use by a landlord and tenant of a new lease who wish to enter into an election to fix the amount of expenditure allocated to fixtures for capital allowances purposes. This Precedent was produced in partnership with Steven Bone.

This Precedent section 198 Capital Allowances Act 2001 (CAA 2001) election is for use by the buyer and seller of an existing interest in real estate who wish to enter into an election to fix the amount of the sale price allocated to fixtures for capital allowances purposes. This Precedent was produced in partnership with Steven Bone.