38 |
simply chattels—so that a human corpse is not goods.354 In Buckingham v Securitas Properties Ltd355 a security firm constructed a special area in which bulk coins and notes were broken down into individual wage packets. The court held that the notes and coins were not ‘goods’; if they had been goods the court would have held that they were not being ‘subjected to any process’. A similar approach was adopted in Girobank plc v Clarke356 where a document or data processing centre did not qualify. In Bestway Holdings Ltd v Luff357 the court held that goods were not subjected to a process where they were checked and packaged as part of a cash and carry warehouse operation. A building used for the maintenance or repair of goods will qualify if the goods or materials are employed in a trade or undertaking which itself qualifies.358 |
24A.3.2.2 Storage |
| Head 3 of Table A refers to a storage, ie a trade consisting of (a) storing359 goods or materials which are to be used in the manufacture of other goods or materials, (b) which are to be subject to a process, or (c) which have been manufactured or processed awaits delivery to a customer. The trade will also qualify if (d) it is for the storage of goods or materials on arrival in the UK from a place outside the UK. The word ‘storage’ has been held to indicate that the category was confined to buildings in the vicinity of an airport or seaport and to facilities needed in the ordinary process of physically transporting goods (so not extending to quarantine kennels).360 Stockists can claim allowances provided they carry on the trade of storing goods.361 The test is whether the building is used for the purposes of a trade which consists in the storage of qualifying goods, and not whether the building is used for the storage of such goods.362 An allowance can therefore be claimed for a building even though it is also used in part for the storage of other goods.363 So while a warehouse used for the storage of tyres before being remoulded qualified as an industrial building,364 a cash and carry ware house did not; in the first case the storage was part |