HMRC internal manual

Capital Allowances Manual

CA22070 - Plant and Machinery Allowances (PMA): buildings and structures: floors

Floors are in item 1 of List A, S21 (see CA22010) and are therefore excluded from PMAs and so you should refuse a claim for plant and machinery allowances on a floor. Refuse a claim for allowances on raised and mezzanine floors. The legislation applies to them like any other floor. In the Wimpy  case (CA21140) the companies claimed plant and machinery allowances on raised and mezzanine floors. The refusal of the claims was upheld in the Courts. These floors were part of the premises.

You should give plant and machinery allowances on a temporary floor put down solely to enable the room to be used for dancing and on a plenum floor, which is a floor that forms part of the reticulation system of a heating or air conditioning system. For example, it may form the fourth side of a duct of channel through which stale air is extracted for treatment. Other floors covering heating and ventilation systems and computer cabling are not plant just as suspended ceilings are not plant.

In the cases of Hunt v Henry Quick Ltd and King v Bridisco Ltd 65TC108  the companies claimed plant or machinery allowances on mezzanine platforms used for storage in warehouses. The Commissioners found that the mezzanine platforms were movable temporary structures used for storage. The mezzanine platforms had not become part of the premises. The kind of expenditure incurred in these cases is covered by the reference to ‘storage equipment’ at CAA01/S23 but if a mezzanine platform functions as a floor rather than storage equipment it will be excluded by CAA01/S21. The fact that a mezzanine floor is not part of the premises is irrelevant. S.21 defines buildings as including assets which are not incorporated in a building but are of a kind normally incorporated in a building.

A mezzanine platform is either a floor or a large shelf (storage equipment) and will rarely, if ever, be both and so the claim either fails or it succeeds in full. Please contact a capital allowances technical adviser in Business, Assets and International (BAI) before accepting that expenditure on floors qualifies in part.