Capital allowances for fixtures - ATT comments

The Association is please to have the opportunity to comment on this consultation.

The ATT comments, sent to HMRC on 26 August 2011, on HMRC's consultation entitled 'Capital allowances for fixtures'. This document plus the consultation to which it refers are available here in Adobe (pdf) format.


As announced in the Budget in March, the Government is considering a ‘mandatory pooling’ proposal, under which businesses must pool their expenditure on fixtures in a building within a short period of acquiring the building in order to qualify for allowances. Further it is proposed that, in order to qualify for capital allowances, the purchaser of a second hand building must agree with the seller the amount of the sale price attributable to fixtures and notify this to HMRC (ie a procedure similar to section 198 elections would become compulsory).

These proposals are intended to give effect to the underlying policy that expenditure on a qualifying fixture should be written-off against taxable profits only once over its economic life.

Technical Team

26 August 2011