CA21170 - Plant and Machinery Allowances (PMA): meaning of plant and machinery: mains services overview

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.

As indicated in CA21150, the ‘completeness test’ is no longer relevant in relation to electrical systems and other assets defined as ‘integral features’, but it may need to be considered in relation to gas and sewerage systems.

The ‘completeness test’ does not let you refuse all claims that gas or sewerage systems qualify for capital allowances as plant or machinery.

In Cole Brothers Ltd. v Phillips 55TC188 Oliver L J said this:

‘A building may be incomplete without some form of electrical installation but if the occupier installs a system specially adapted for the particular purpose for which he intends to use the building the fact that the building would be incomplete if the electrical system were to be removed does not prevent the electrical system being plant.’

In the Cole Brothers case, the taxpayer claimed that the electrical installation in a new retail store should be treated as a single item of plant. The inspector took a piecemeal approach by looking at the components separately and the courts took the same approach.