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HMRC internal manual

Capital Allowances Manual

Plant and Machinery Allowances (PMA): meaning of plant and machinery: completeness test

For expenditure incurred on or after 1 April 2008 (CT) or on or after 6 April 2008 (IT) see the guidance on integral features starting at CA22300.

Another test that is sometimes applied in deciding whether an item is plant is the ‘completeness test’. You apply the ‘completeness test’ to an asset in a building by considering whether the building would be complete for the carrying on of the activity that is to be carried on within it without that item. It is the same test as the third of the four general factors Hoffman said should be considered CA21140 in deciding whether an item has become part of the premises.

The ‘completeness’ test was considered by the House of Lords in the case of* Cole Brothers Ltd. v Phillips 55TC188*. In that case Vinelott, J said that he considered the ‘completeness’ test to be implicit in the J Lyons case where Uthwatt J drew a distinction between lighting which was added to a building which was otherwise complete to be used for its intended purpose and lighting which was needed to make a building complete for its intended purpose. Lighting which was added to an otherwise complete building might be plant; lighting which was needed to make a building complete for its intended purpose was not plant. For example, if there is not enough natural light for the building to be usable the electric lighting that makes the building usable is not plant (but see CA21170).