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HMRC internal manual

Capital Allowances Manual

Plant and Machinery Allowances (PMA): meaning of plant and machinery: football ground improvements

In past years football clubs may have incurred expenditure on ground improvements in order to implement the recommendations of the Taylor report. The Inland Revenue had discussions with the Football League about what expenditure was likely to qualify for capital allowances. Following those discussions the Inland Revenue sent the Football League a letter on 25 January 1991 indicating what expenditure was likely to qualify. The letter listed as an appendix the sort of assets used by a football club in its trade that would normally qualify as plant or machinery. The list can be found below. Many but not all of the items listed qualify as plant under the current legislation, the rate of WDA will depend on the particular asset. As with all cases concerning the plant/premises divide and the question of whether or not an asset qualifies for PMAs the requirement is to identify the particular function of the particular asset in the particular trade and to then apply the statutory tests in Sections 21 to 23 CAA 2001.

This is the list:

  1. Advertising hoardings and perimeter boards which are not simply part of a perimeter fence or other structure
  2. Air conditioning plant, fans and ventilation machinery
  3. Automatic exit doors and gates
  4. Bicycle holders
  5. Cameras, televisions, video recorders
  6. Cars, coaches and vans
  7. Computers, printers, photocopiers, typewriters and cash registers
  8. Cookers, fridges, freezers, microwaves, dishwashing machines
  9. Crush barriers securely fixed to the ground are not plant or machinery but they may come within the 1975 safety legislation and so qualify under CAA01/S32 CA22240 
  10. Electric scoreboards and visual displays
  11. Fencing is not plant or machinery but it may come within the 1975 safety legislation and so qualify under CAA01/S32 CA22240 
  12. Fire alarm systems, fire extinguishers, sprinkler systems
  13. Floodlighting
  14. Floor coverings that are not part of the building or structure; for example, carpets (but not tiles which are stuck down)
  15. Goalposts and certain movable training equipment of a capital nature, for example, a vaulting horse (but not equipment which is part of the premises)
  16. Heating installations, boilers and water heaters
  17. Lifts and hoists
  18. Public address equipment - microphones, amplifiers and loudspeakers
  19. Racking, shelving, cupboards and furniture
  20. Telephones and telephone equipment, for example, private exchanges.
  21. Toilet sanitary ware, sinks and basins, baths and showers whether for staff or public (but not the mains water supply)
  22. Turnstiles and spectator counting equipment

The letter gave some guidance on seats. It said that most modern types of seats are likely to qualify as plant or machinery, both plain plastic tip-up seats and more luxurious types of seat. It makes it clear that seating which is no more than an integral part of the stand will not qualify.

It says that the incidental costs of installing seats, or any other type of plant or machinery, may qualify under CAA01/S25 (CA21190). It says that expenditure will not qualify as incidental if it creates an essentially new asset such as a stand or a terrace with an entirely new rake. It also says that we would not expect expenditure to qualify as incidental if it is large in proportion to the cost of the plant or machinery being installed.

Remember that not all expenditure incurred by clubs to comply with the requirements of the Football Spectators Act 1989 will qualify for capital allowances. The normal rules will apply.

The letter states that expenditure on the fabric of a police control box will not qualify for capital allowances. We have now been advised that some local authorities take the view that they have the power under the Safety at Sports Grounds Act 1975 to require police control rooms to be installed. If that happens the expenditure will qualify under CAA01/S32 (CA22240).