Steven Bone
Steven is a tax-qualified chartered surveyor. He has specialised in capital allowances for more than 25 years, and more recently land remediation relief and R&D tax incentives.
In his role as director at Gateley Capitus, Steven works with businesses that are buying, building or refurbishing commercial property, cleaning-up contaminated land and buildings or undertaking R&D activity to help them pay the right amount of tax by optimising the tax reliefs available to them.
Prior to joining Gateley Capitus, Steven held senior roles in the Big 4, specialist boutique and national mid-tier accountancy firms. He is a fellow of the Royal Institution of Chartered Surveyors (RICS) and the Association of Taxation Technicians.
Alongside daily practice, Steven is a tax incentives writer and speaker for property investment and innovation activity.
Practice Area
Panel
- Contributing Author
Qualified Year
- 1995
Experience
- Azets (2004 - 2019)
- Deloitte (2002 - 2004)
- Arthur Andersen (1997 - 2002)
Membership
- Fellow of the Royal Institution of Chartered Surveyors, FRICS
- Fellow of the Association of Taxation Technicians, ATT (Fellow)
Qualifications
- Business Administration (PGDip) (2010-2010)
- Quantity Surveying BSc (Hons) (1989-1993)
Education
- University of Warwick – Warwick Business School (2010-2010)
- Liverpool John Moores University (1989-1993)
14 Contributions by Steven Bone
PRACTICE NOTES
CAA 2001 s198/s199 fixtures elections in UK property transactions: apportionment of consideration, fixed value requirement, buyer/seller positions, HMRC requirements, deadlines and pitfalls
FORTHCOMING CHANGES:
At Budget 2025, the government confirmed Finance Bill 2026 measures:
Main pool writing‑down allowances fall from 18% to 14% from 1 April 2026 (CT) and 6 April 2026 (IT), impacting companies and unincorporated businesses, including pre‑FYA expenditure.
A 40% first‑year allowance for qualifying main rate spend incurred from 1 January 2026, with fewer restrictions than other FYAs; it mainly helps costs outside the £1m AIA or existing FYAs, applies to all businesses, includes assets used for leasing (not overseas), and excludes cars and second‑hand assets.
100% green FYAs for zero‑emission cars and EV charging points extended to 31 March 2027 (CT) and 5 April 2027 (IT).
The Practice Note outlines section 198/199 CAA 2001 elections for fixtures transferred on property sales or new leases. Default treatment is a just and reasonable apportionment, or the parties may jointly fix the value within two years. Elections are irrevocable, capped at the seller’s original cost, require clear identification of the land, fixtures and amount, and only apply where the seller has pooled qualifying expenditure or claimed a first‑year allowance. Invalid or missing elections risk clawback for sellers and may leave buyers unable to claim without a timely First‑tier Tribunal determination...
Tax
PRACTICE NOTES
Capital allowances due diligence on UK property transactions: essential pre-contract enquiries, pooling and fixed value rules, fixtures elections, tenant contributions and structures and buildings allowances
FORTHCOMING CHANGES
At Budget 2025, the government set out measures to be legislated in Finance Bill 2026, namely:
a reduction in the writing‑down allowance rate on main pool plant and machinery from 18% to 14%, effective 1 April 2026 for corporation tax and 6 April 2026 for income tax—affecting companies and unincorporated firms with main rate pools, covering expenditure that does not qualify for, or predates, first‑year allowances such as the super‑deduction and full expensing
a new 40% first‑year allowance for qualifying main rate expenditure incurred from 1 January 2026, with fewer restrictions than other FYAs—mainly helping spend not eligible for the £1m annual investment allowance or existing FYAs (eg full expensing); available to all businesses, and covering assets used for leasing (excluding overseas leasing), but excluding cars and second‑hand assets
a one‑year extension of the 100% green first‑year allowances for qualifying spend on zero‑emission cars and electric vehicle charging points to 31 March 2027 for corporation tax and 5 April 2027 for income tax
This Practice Note covers capital allowance due diligence before contract on property transfers, including the grant of a new interest (eg a lease) and the purchase of an existing lease or freehold...
Tax
PRACTICE NOTES
UK capital allowances on fixtures: definition, land interests, second-hand acquisitions, fixed value and pooling rules, CAA 2001 s 198/199 elections, tribunal determinations, just and reasonable apportionment
Tax relief for expenditure on fixtures
A taxpayer can often obtain tax relief for expenditure on fixtures by claiming plant and machinery allowances. For wider guidance on the availability of plant and machinery allowances in general, see Practice Note: Plant and machinery allowances—types and rates, and for further detail on how allowances are claimed and calculated, see Practice Notes: How plant and machinery allowances are claimed—income tax and How plant and machinery allowances are claimed—corporation tax. To qualify for allowances, expenditure on fixtures must satisfy the same conditions that apply to other categories of plant, together with additional rules that are specific to fixtures...
Tax
PRACTICE NOTES
UK capital allowances on integral features: definitions, special rate, repairs 50% test, anti-avoidance, property sale elections and 2026 reforms
FORTHCOMING CHANGES:
At Budget 2025, the government outlined measures to be enacted via Finance Bill 2026:
A reduction in the writing-down allowance rate for main pool plant and machinery from 18% to 14%, taking effect on 1 April 2026 for corporation tax and 6 April 2026 for income tax—affecting both companies and unincorporated businesses with main rate pools, including spend that does not qualify for, or predates, FYAs such as the super-deduction and full expensing.
A new 40% first-year allowance for qualifying main rate expenditure incurred from 1 January 2026, with fewer limitations than other FYAs—principally advantageous where the £1m AIA or existing FYAs (such as full expensing) are not available. It will apply to all businesses and include assets used for leasing (excluding overseas leasing); cars and second-hand assets are excluded.
An extension of the 100% green first-year allowances for qualifying zero-emission cars and electric vehicle charging points by one year to 31 March 2027 for corporation tax and 5 April 2027 for income tax.
Together, these changes reshape relief for main pool expenditure while enhancing upfront relief for targeted investments where AIA or current FYAs are otherwise inaccessible…
Tax
PRACTICE NOTES
UK Capital Allowances: Capital/Revenue Distinction, Enduring Benefit, Entirety, Nearest Modern Equivalent, Integral Features and the Law Shipping Principle
What are capital allowances?
Capital allowances provide tax relief for certain, though not all, items of capital expenditure. They function as a standardised, tax‑deductible stand‑in for depreciation or amortisation, broadly intended to deliver relief that mirrors the economic life of business assets. For income or corporation tax returns, accounting depreciation is not deductible; capital allowances are claimed instead. Eligibility is restricted and some assets are excluded. For example, spending on land does not qualify. The most frequently encountered allowances are for plant and machinery. The scope of plant and machinery for capital allowance purposes is set out in Practice Note: Plant and machinery allowances—definition of plant and machinery. Since October 2018, relief has also been available for specified expenditure on structures and buildings, or parts of them, where their construction is treated as commencing on or after 29 October 2018; see Practice Note: Structures and buildings allowances. Capital allowances may grant full relief at the time the cost is incurred, but relief is often apportioned across several years, using a range of allowance types applied at differing rates. The timing and rate of relief depend on the specific allowance claimed...
Tax
PRACTICE NOTES
UK capital allowances: connected persons definitions, transfer rules and anti-avoidance for plant and machinery, integral features, and structures and buildings
Safeguards are in place to prevent, in broad terms, the movement of assets between connected parties in a manner that speeds up capital allowances via the annual investment allowance or first-year allowances, or that deliberately contrives to overstate the figure on which relief is available by any artificial means whatsoever.
This Practice Note explains how the capital allowances regime defines connected persons and also sets out how those provisions operate when assets pass between such persons.
For further guidance and detail on an election permitting alternative treatment where a trade is transferred between connected persons, see Practice Note: Capital allowances and company reconstructions—Transfer of a trade between connected persons in practice.
For an overview of the computation of capital allowances for plant and machinery, including, in particular, the meanings of annual investment allowance, first-year allowances, disposal value and writing down allowance, refer to Practice Notes: How plant and machinery allowances are claimed—income tax and How plant and machinery allowances are claimed—corporation tax.
For a discussion of how allowances for structures and buildings are determined, see Practice Note: Structures and buildings allowances...
Tax
PRACTICE NOTES
UK Corporation Tax: Land Remediation Relief for Contaminated and Derelict Land—Eligibility, 150% Deductions, Tax Credits, Exclusions and 2024–2025 Policy Developments
What is land remediation relief? (LRR)
LRR provides corporation tax relief on expenditure incurred in remediating contaminated land or in bringing derelict sites back into use. In 2009, the regime was broadened to address market failure by returning long-term derelict land to use, bringing such sites back into use. An incentive applies where land, whose development has been affected by various kinds of continuing dereliction, is brought back into productive use. The extension was intended to correct market failure by encouraging activity on sites blighted by ongoing dereliction. The relief was at risk of being discontinued after 2012; however, the 2012 Budget confirmed it would continue.
The October 2024 HM Treasury Corporate Tax Roadmap, published alongside Autumn Budget 2024, notes the new Labour government’s commitment to a brownfield-first approach, prioritising the development of previously used land wherever possible. Given the time since the last review of LRR, and the potential for it to help progress the government’s objectives, the Roadmap announced that a consultation would be launched to review the effectiveness of the relief. The Autumn Budget also noted the launch of the consultation, to consider whether the relief is still meeting its objectives and is good value for money...
Environment
PRACTICE NOTES
UK corporation tax: plant and machinery capital allowances—qualifying expenditure, pooling, writing-down and first-year allowances, disposals and balancing charges, claims, time limits and loss relief
FORTHCOMING CHANGES:
At Budget 2025, the government confirmed that Finance Bill 2026 will legislate for:
a cut in the writing-down allowance rate for main pool plant and machinery from 18% to 14%, applying from 1 April 2026 for corporation tax and 6 April 2026 for income tax—this will affect companies and unincorporated businesses with main rate pools, including expenditure that is ineligible for, or predates, first-year allowances (such as the super-deduction and full expensing)
a new 40% first-year allowance for qualifying main rate expenditure incurred from 1 January 2026, with fewer restrictions than other FYAs—primarily advantageous where spend is not otherwise covered by the £1m AIA or existing FYAs (including full expensing); available to all businesses and covering assets used for leasing (but not overseas leasing), while excluding cars and second-hand assets
a one-year extension of the 100% green first-year allowances for qualifying spend on zero-emission cars and electric vehicle charging points, to 31 March 2027 for corporation tax and 5 April 2027 for income tax
...
Tax
PRACTICE NOTES
UK plant and machinery capital allowances: types, rates, AIA, first‑year allowances (super‑deduction, full expensing), special‑rate, short‑life and long‑life assets, with 2026/27 updates
FORTHCOMING CHANGES:
At Budget 2025, the government set out measures to be legislated in Finance Bill 2026.
From 1 April 2026 for corporation tax and 6 April 2026 for income tax, the main pool writing-down allowance will drop from 18% to 14%. This affects companies and unincorporated businesses with main rate expenditure, including items that do not qualify for, or pre-date, FYAs such as the super-deduction and full expensing.
A new 40% first-year allowance will apply to qualifying main rate expenditure incurred from 1 January 2026. With fewer restrictions than other FYAs, it is expected to assist spend not otherwise eligible for the £1m AIA or existing FYAs (such as full expensing). It will be available to all businesses, will cover assets used for leasing (but not overseas leasing), and will exclude cars and second-hand assets.
The 100% green first-year allowances for qualifying zero-emission cars and electric vehicle charging points will be extended by one year to 31 March 2027 for corporation tax and 5 April 2027 for income tax.
Capital allowances provide tax relief on certain capital costs, typically over time, with accelerated reliefs available; plant and machinery remains the most advantageous category...
Tax
PRACTICE NOTES
UK Structures and Buildings Allowances: qualifying expenditure, entitlement, rates, mixed use, leases, exclusions, anti-avoidance, CGT interaction and allowance statement requirements
This Practice Note covers structures and buildings allowances (SBAs), being allowances for capital outlay on non-residential structures and buildings that are constructed, refurbished or converted on or after 29 October 2018. SBAs may apply where plant and machinery allowances do not. In the Corporate Tax Roadmap issued alongside the Autumn Budget 2024 on 30 October 2024, the government confirmed it would preserve the structures and buildings allowance for the remainder of this Parliament. There are specific provisions for SBAs in freeports—see Practice Note: Freeports in England—tax features—as well as for SBAs in investment zones.
Qualifying expenditure
SBAs are available for capital expenditure incurred on or after 29 October 2018 on:
the construction of a non-residential building or structure, provided construction activity commenced on or after 29 October 2018 and no contract for works to be undertaken in the course of constructing that particular building or structure was entered into before that date
the acquisition of a non-residential building or structure (or a relevant part) the construction of which began on or after 29 October 2018, where the asset is acquired:
unused from a party other than
...
Tax
PRECEDENTS
Agreement for lease clause: UK capital allowances on landlord’s contribution (CAA 2001—tenant’s works, plant/special rate plant, and structures and buildings allowances)
1 Capital allowances
1.1 In this clause 1:
CAA 2001 denotes the Capital Allowances Act 2001.
Plant or Machinery refers to items within the Tenant’s Works that qualify as plant or machinery for the purposes of Part 2 of CAA 2001.
Landlord’s Contribution is £[ insert figure ] plus VAT (if any).
SBA Assets describes those elements of the Tenant’s Works where the expenditure qualifies for structures and buildings allowances under Part 2A of CAA 2001.
Special Rate Plant means Plant or Machinery for which the spend would be treated as special rate expenditure under CAA 2001, s 104A.
Tenant’s Works means the Tenant’s [ fitting out works ] to be carried out at the...
Tax
PRECEDENTS
Precedent capital allowances clauses for property sale contracts (UK): fixtures elections (CAA 2001 ss198/199), Tribunal apportionment, pooling/warranties, and structures and buildings allowances
1 Capital allowances—for use where the Seller has claimed a first-year allowance or pooled qualifying expenditure on plant and machinery fixtures and the parties will enter into a s 198/s 199 joint fixtures election on completion
In this clause 1:
CAA 2001 means the Capital Allowances Act 2001;
Fixtures means all plant and machinery installed or otherwise affixed in or to the Property so as to become part of the Property at law, including any boiler or water‑filled radiator under section 173(1) of CAA 2001;
HMRC means HM Revenue & Customs;
Main Pool Plant means those Fixtures included by the Seller in the main pool under section 54 of CAA 2001;
Prior Right has the meaning of prior right for the purposes of section 181(2) of CAA 2001;
Special Rate Pool Plant means those Fixtures included in a special rate pool under section 104C of CAA 2001.
On Completion, the Seller and the Buyer shall make an election concerning the Fixtures under section 198 of CAA 2001, using the form attached at Schedule [ insert reference ] (the “Election”), and shall each, within [ insert number
...
Tax
PRECEDENTS
Precedent: section 198 CAA 2001 joint election fixing consideration for fixtures (plant and machinery) on sale of land (special and main rate pools, super-deduction and full expensing)
[ Date ]
[ Transferor's name and Unique Taxpayer Reference (UTR) ]
[ Transferee's name and UTR ]
Election to apportion the price of fixtures under section 198 of the Capital Allowances Act 2001
Please take notice that a joint election has been made in accordance with section 198 of the Capital Allowances Act 2001 (CAA 2001). This election is entered into by [ name of transferor ], as transferor (the Transferor), whose Unique Taxpayer Reference is [ UTR ], together with [ name of transferee ], as transferee (the Transferee) whose Unique Taxpayer Reference is [ UTR ].
The election concerns the property identified as [ details of property and the address ], recorded with HM Land Registry under title number [ title number ] (the Property)...
Tax
PRECEDENTS
Section 199 CAA 2001 election to apportion price of fixtures on grant of lease: template with appendix, including super‑deduction and full expensing (England and Wales)
[ Date ]
[ Grantor's name and Unique Taxpayer Reference (UTR) ]
[ Grantee's name and UTR ]
Election to apportion the price of fixtures under section 199 of the Capital Allowances Act 2001
This serves as formal notice of an election entered into under section 199 of the Capital Allowances Act 2001 (CAA 2001). This joint election is entered into by [ name of grantor ], acting as grantor (the Grantor), whose Unique Taxpayer Reference is [ UTR ], together with [ name of grantee ], acting as grantee (the Grantee), whose Unique Taxpayer Reference is [ UTR ], in relation to the property described as [ details of property and the address ], recorded at HM Land Registry with title number [ title number ] (the Property)...
Tax
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