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HMRC internal manual

Capital Allowances Manual

PMA: Fixtures: Changes in ownership: Conditions for allowances


When a person (the current owner) is treated as owning a fixture as a result of incurring qualifying expenditure on the provision of it, and another person (the past owner CA26474) has previously been treated as owning the fixture, the availability of capital allowances to the current owner, if the past owner was entitled to allowances, is conditional on

  • the past owner pooling their qualifying expenditure in respect of the fixture prior to transfer (‘pooling requirement’ CA26476
  • the ‘fixed value requirement’ (CA26478) or ‘disposal value statement requirement’ (CA26482), whichever is applicable, being met.  

The ‘fixed value requirement’ is met by the past owner and current owner formally agreeing a value for the fixture within two years of transfer, or by commencing formal proceedings within that time to agree the value, or in certain circumstances by written statements being supplied (CA26478)

The ‘disposal value statement requirement’ applies in exceptional circumstances and is met by the past owner providing a written statement, within two years of his cessation of ownership, of the amount of the disposal value of fixtures which he had some time earlier been required to bring into account (for example, when he permanently ceased his business) (CA26482).