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HMRC internal manual

Capital Allowances Manual

HM Revenue & Customs
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Plant & Machinery Allowances (PMA): Long-life assets: Exclusions

CAA01/S93 - S96

Long-life asset treatment does not apply to expenditure:

  • on the provision of plant or machinery which is a fixture in, or is provided for use in, a building used wholly or mainly as, or for purposes ancillary to the purposes of, a dwelling house, retail shop, showroom, hotel or office.
  • incurred before 1 January 2011 on the provision of ships of a sea-going kind other than ones which:

    • are of a type primarily used for sport or recreation, or
    • are offshore installations for the purposes of the Mineral Workings (Offshore Installations) Act 1971, such as oil rigs or gas installations, or
    • would be offshore installations if the activities for which they are used or to be used were carried on in controlled waters.

      • incurred before 1 January 2011 on the provision of railway assets for use wholly and exclusively in a railway business.
      • on the provision of cars as defined in CAA01/S81 or CAA01/S268A CA23510.


    The list of excluded buildings is the same as the list in CAA01/S277 of buildings that are not industrial buildings for IBA CA32310. The wholly or mainly condition is similar to the 25% rule in CAA01/S283 CA32700 but it is wider than it. The 25% rule treats the whole of a building as an industrial building if the cost of constructing the parts that are not used for a qualifying trade is not more than 25% of the cost of constructing the whole building. You should accept that the wholly or mainly condition is satisfied if at least 75% of the building measured on a reasonable basis, for instance by cost or floor area, is used for purposes within the list of excluded buildings.

    The definition of ships that are excluded from long-life asset treatment is broadly the same as the definition of qualifying ships for rollover relief CA25350 except that there is no registration or weight requirement.

    The definition of a railway includes a tramway or other system of guided transport. Railway assets are locomotives, rolling stock, tracks, stations, light maintenance depots, signalling equipment, power supplies and other associated apparatus. A railway business is a business or the part of a business that provides a public service of transporting goods or passengers by means of a railway in the UK or the Channel Tunnel. Expenditure on the provision of a railway asset for use (whether by the owner or by a lessee) wholly and exclusively for the purposes of a railway business is excluded from long-life asset treatment. Expenditure which involves a benefit to a non-railway business may satisfy the wholly and exclusively condition if the benefit is incidental (see BIM42135), for instance an electricity generator to supply power to a railway system which also incidentally supplies power to shops on railway stations. Parts of a station which are intended to be used to a material extent for other purposes are likely to fail the wholly and exclusively condition but may come within the shops and offices exclusion instead.