Capital Allowances

25

particular item of plant is energy efficient and may also impose limits in situations in which the energy efficient plant is part of a larger item.214 The allowance is available to all companies regardless of size. The allowance is simply part of the scheme in part II of the Act and so general rules excluding FYAs in certain situations apply but this is spelt out.215

The fixture rules are also used to make the new allowances available where an energy services provider, as defined, provides services under an energy services agreement, as defined.216 The provider may claim the allowances even though not owning the plant since it has become part of the land.217

24A.2.6    Writing down Allowances, Balances and the Pool

The writing down allowance, which is given on a 25% reducing balance basis, applies where the taxpayer, T, incurs capital expenditure on the provision of Plant and Machinery wholly and exclusively for the purposes of the trade. In addition, the asset must be owned by T. It is not necessary that the asset should have been brought into use in the trade. If the chargeable period is greater or less than 12 months the figure of 25% is increased or reduced accordingly.218

24A.2.6.1    Pooling

Although practitioners had talked for years of pools and pooling these terms did not become part of the statutory language until CAA 2001. Generally, all Plant and Machinery used in the trade is placed in one pool—the main pool—and the writing down allowance is applied to the value of that pool as a whole.219 However, certain items must be pooled separately. The first group form single asset pools, which naturally means that only expenditure to that asset is relevant.220 These are:

  1. ‘expensive’ road vehicles;221
  2. short life assets;222
  3. ships;223 (here the law allows deferments of writing down allowances at will);
  4. assets used partly for non-qualifying purposes;224
  5. assets the wear and tear on which is subsidised;225There are also class pools for two groups of assets which attract a lower rate of write off
  6. long life assets (6%);226 and
  7. overseas leasing (10%).227

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