Richard Curtis reviews a recent First-tier Tribunal decision on entitlement to capital allowances on buildings and structures and HMRC’s thinking on the subject.
The question of capital allowances on buildings and structures came to the fore recently in JRO Griffiths Ltd v Revenue and Customs [2021] UKFTT 257 (TC), which offers a good review of the issues at play.
To summarise, in the accounting period ended 31 March 2015, the company, which sold potatoes to crisp manufacturers, spent just over £300,000 on a potato storage warehouse, and claimed capital allowances. Following an enquiry, HMRC disallowed the claim and the company appealed.
Qualifying conditions
The tribunal neatly summarised the conditions for claiming plant and machinery allowances (with all references following relating to CAA 2001):
- A
