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HMRC internal manual

Capital Allowances Manual

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

F2A92/S40A - S40D

The legislation makes expenditure on master versions of films revenue expenditure as a general rule. This means that it cannot be qualifying expenditure and so it cannot qualify for PMAs.

There is one exception to this. A person whose trade includes the exploitation of master versions of films and who incurs expenditure on the production or acquisition of a master version of a film may elect to have the expenditure treated as capital expenditure The expenditure on the film can then qualify for PMAs.

An election may only be made if:

  • the film is certified by the Secretary of State under Schedule 1 of the Films Act 1985 as a qualifying film; and
  • the value of the film is expected to be realisable over a period of not less than two years.


The election must:

  • be made in writing to the Inspector within two years of the period of account in which the film is completed; and
  • relate to all the expenditure incurred, or to be incurred, on the production of the film to which the election applies.


Once an election has been made it is irrevocable.

The master version of a film is completed at the time when it is first in a form in which it can reasonably be regarded as ready for copies of it to be made and distributed for presentation to the general public. Where the film was acquired after that time it is completed at the time it was acquired.

An election cannot be made where a claim for relief has been made under any of the other provisions that apply to qualifying films (see BIM56310 onwards).