Capital allowances ― property transactions and fixtures

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Owner-Managed Businesses

Guidance

Definition of fixtures

A fixture is defined for capital allowance purposes as plant or machinery that is installed or fixed in or to a building or land so as to become, in law, part of that building or land and also specifically includes any boiler or water-filled radiator installed in a building as part of a space or water heating system. Examples of fixtures include:

•
lifts and escalators
•
heating, lighting and electrical systems
•
alarm systems
•
sanitary appliances, and hot and cold water systems
•
telephone and data installations

CAA 2001, s 173

However, the definition of fixtures is much wider than the list shown above and can include, for example, individually small items such as signs and door furniture. Consequently, it is practically inconceivable that a building will not contain assets on which capital allowances could potentially be claimed.

Indeed, it is often easier to define what is not a plant and machinery fixture. In the context of a property transaction, any expenditure

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Martin Wilson

Martin Wilson, specialised in capital allowances for 25 years before retirement. He is the author of numerous published works on the subject, including Bloomsbury's Capital Allowances: Transactions & Planning, and the capital allowances content of LexisPSL, Tolley's Tax Guidance, Tolley's Tax Planning and Simon's Tax Planning.

Steven Bone

Director at Gateley Capitus

Steven is a tax-qualified Chartered Surveyor who has specialised in tax incentives, including capital allowances and land remediation relief for over 20 years. Previously he held senior specialist positions in 'Big 4' and national mid-tier accountancy firms. Capital allowances underpin income tax and corporation tax calculations by giving tax relief for money spent to buy, build or alter commercial property.Steven works with owner-occupiers, investors and their advisers to provide capital allowances opinions, transaction support and specialist valuations for all types of property. This includes resolving HM Revenue capital allowances enquiries and giving expert evidence to tribunals and courts.Steven has contributed to many articles and books, including: Bloomsbury Professional's Capital Allowances, Tolley's Tax Planning, RICS's official Guidance Note for surveyors on Capital Allowances and Land Remediation Relief, and Practical Law Company's Practice Note on Commercial Property Standard Enquiry 32 dealing with capital allowances.

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