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HMRC internal manual

Capital Allowances Manual

IBA: Qualifying trade: Transport undertaking

An undertaking is a transport undertaking if its primary activity is the provision of transport. It does not matter if the transportation is the transportation of goods or passengers or how the transportation is done. A transport undertaking will normally be carried out by a person acting as a common carrier, that is, people holding themselves out as providing a service of transporting goods or passengers to any person wishing to use their services. Examples of persons carrying on a transport undertaking are:

  • someone who operates a taxi service;
  • a railway or bus company;
  • an airport operator. If you deal with an IBA claim from an airport operator you should remember that not all of the activities of an airport operator will qualify as the operation of a transport undertaking and so not all buildings will qualify for IBA. For example, the airport operator may provide extensive shopping facilities and the provision of shopping facilities is not the operation of a transport undertaking;
  • organisations like the Post Office which provide a service of transporting mail and parcels; that service is a part trade of transport undertaking.


A firm, which uses transport in the course of another trade, is not carrying on a transport undertaking. For example, a wholesaler who runs a fleet of vehicles for collecting and delivering his trading stock is not carrying on a transport undertaking. The primary activity is the buying and selling of goods, the transportation of those goods being ancillary to the primary activity. A person who hires out vehicles alone rather than vehicles with drivers is not carrying on a transport undertaking nor is the operator of a toll bridge, tunnel or road.