Commentary

B3.276 Structures and buildings allowance—co-ownership authorised contractual schemes

Business tax
Business tax | Commentary

B3.276 Structures and buildings allowance—co-ownership authorised contractual schemes

Business tax | Commentary

B3.276 Structures and buildings allowance—co-ownership authorised contractual schemes

Where the participants in a co-ownership authorised contractual scheme (CoACS — see D8.146) together carry on a qualifying activity, each participant is treated for the purposes of the structures and buildings allowance (SBA) as carrying on the activity to the extent that the profits or gains arising to him from the activity are chargeable to tax (or would be chargeable if there were any profits)1. In determining whether or to what extent the participants are together carrying on a qualifying activity, it must be assumed that profits or gains arising to all the participants from the activity are chargeable to tax (or would be if there were any)2.

The operator of a CoACS may, however, make an election under which it will calculate SBA on the basis that it

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