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HMRC internal manual

Capital Allowances Manual

Plant and Machinery Allowances (PMA): buildings and structures: cold stores

A refrigerated building, which is used as a cold store, may be incapable of an independent existence as a building. That is, it may consist of a refrigeration unit plus a framework and the framework may be incapable of a separate existence as a building. In that case the whole is effectively a large fridge that qualifies as plant. Pre the abolition of IBA the taxpayer could claim whichever allowance (IBA or plant and machinery) was preferred. However, where the building houses an insulated ‘box’, which provides the insulation, and the building, is capable of an independent existence, it is only the insulated box within the building or structure that qualifies as plant or machinery. In past years the building itself may have qualified for IBA. IBA was abolished for chargeable periods ending on or after 1 April 2011 for businesses within the charge to CT and 6 April 2011 for business within the charge to IT.