Martin Wilson
A former Chartered Accountant, now retired, Martin is the author of more than a dozen books on capital allowances, including Bloomsbury Professional's Capital Allowances: Transactions and Planning. Martin co-founded The Capital Allowances Partnership Limited after 15 years with leading accounting firms, where he headed up the specialist capital allowances practice. He has personally advised some of the UK's leading companies, as well as a myriad of private investors, both in the UK and overseas.
7 Contributions by Martin Wilson
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 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
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
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