The following Tax practice note Produced in partnership with Martin Wilson provides comprehensive and up to date legal information covering:
Certain items of plant and machinery (see Practice Note: Plant and machinery allowances—definition of plant and machinery) are classified as ‘integral features’ by statute. If an item falls within one of the categories of integral features, it:
does not have to satisfy the usual case law tests for deciding whether an asset constitutes plant and machinery for tax purposes (see Practice Note: Plant and machinery allowances—definition of plant and machinery), and
qualifies for a ‘special’ reduced rate of writing-down allowance of 6% per annum rather than the general plant and machinery rate, which is 18% per annum
This is achieved by allocating expenditure on such items to a ‘special rate pool’ in tax computations. Pooling is explained in Practice Notes: How plant and machinery allowances are claimed—income tax and How plant and machinery allowances are claimed—corporation tax.
Expenditure on integral features may qualify for relief at 100%, instead of at the special rate, if it can be included within the annual investment allowance. For more details, see Practice Note: Plant and machinery allowances—types and rates—Annual investment allowance.
An asset is only classified as an integral feature if new expenditure has been incurred on it on or after 1 April 2008 for corporates or 6 April 2008 for non-corporates.
As a result any expenditure incurred before the rule change, which would be classified as expenditure
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