Why capital allowances need proper consideration in transactions

In our recent Tax Journal article we discuss how FA 2012 introduced the pooling and fixed value requirements, denying allowances to the buyer of a commercial property and to future owners if the vendor does not first ‘pool’ qualifying expenditure.

As the vendor may have bought the property many years earlier, it can be difficult to prove entitlement to claim. One such difficulty is the lack of information about claims made by earlier owners.

The decision in Glais House Care Ltd v HMRC [2019] UKFTT 59 (TC) confirms that claims can be based on amounts that previous owners were required to bring into account as disposal values, whether or not they in fact did so.

Read the full article here.