Football club

Why Did Six Forward Get Involved?

The client is a limited company that owns and runs a football club and related training facilities. The subject property comprised a football ground, on-site training facilities and an off-site training ground. The interest in the land was leasehold so the client was concerned if they could claim capital allowances on leasehold improvements made.

There were considerable improvements to the grounds, stands and facilities as well as the creation of third-generation ‘all weather’ (3G) pitches at the training ground. It was the addition of the specialist 3G pitch that the accountant and client were unsure about so decided to seek advice from a capital allowances specialist.

How Did We Help?

The general improvements were as you would expect to see in such a facility. The uncertainty lay around the specialist material used for the 3G pitches. Normally, sports apparatus used for the purpose of the ‘qualifying activity’ will qualify as capital allowances plant and machinery. The specialist surface could be regarded as both the setting for the business and ‘the means by which that business was carried on’. As it was a means of generating profit (club training ground and also publicly rented out) it could be regarded as plant and machinery capital allowances.

There is legal precedent in that HMRC agreed (Anchor International) that the synthetic carpet on a five-a-side football pitch was considered to be plant as it was the means by which the business generated profits. By undertaking due diligence, fully understanding the legislation and navigating the complexities of prior case law we were able to provide certainty to the accountant and client and reduce any perceived risk of making a capital allowances claim.

Relevant Legislation For This Case

Capital Allowances Act 2001 s.11, s15, s176 & s33A