News – 02.12.24
2024 US tax year end planning for Americans in the UK
The 2023 US tax year ends on 31 December 2023, so now is a good time to consider whether there is anything that you can do to minimise your US tax exposure for 2023 and begin preparing for 2024. … Read more
Insight – 02.12.24
Budget 2024: Reform to the taxation of carried interest
Find out more about the changes coming for capital gains tax and carried interest. … Read more
Upcoming event – 10.12.24
Funding innovation in the technology sector: Are the government doing enough?
Join us for an exclusive roundtable breakfast to explore the question of whether the government are doing enough to support innovation in the technology sector. … Read more
Find us quickly
130 Wood Street, London, EC2V 6DL
enquiries@buzzacott.co.uk T +44 (0)20 7556 1200
The super-deduction applies to companies eligible to claim capital allowances on plant and machinery (P&M). Contracts must be entered into on or after 3 March 2021 and the expenditure incurred between 1 April 2021 and 31 March 2023. Pre 3 March 2021 contracts are excluded, even if the expenditure is incurred after 1 April 2021.
The company must be within the charge to Corporation Tax, and the P&M must be new and not second-hand. The normal exclusions in relation to cars, assets for leasing, ships, connected party transactions, and the standard anti-avoidance provisions apply. There are special rules for the oil and gas sector.
For 130% rate assets, disposal proceeds will be taxed as a balancing charge in the disposal period and not deducted from the capital allowances pool. For disposals before 1 April 2023, the balancing charge will be based on 130% of the proceeds. For disposals in a period straddling 1 April 2023, the proceeds are time apportioned, and the 130% applied to the pre 1 April period.
For assets constructed over a period of time and partly qualifying for 130% allowances and partly under the normal rules, the proceeds are apportioned.
Disposals of 50% assets are dealt with by way of a balancing charge and apportionment, but there is no uplift.
There is the usual raft of anti-avoidance provisions in the draft legislation.
The super-deduction applies to companies eligible to claim capital allowances on plant and machinery (P&M). Contracts must be entered into on or after 3 March 2021 and the expenditure incurred between 1 April 2021 and 31 March 2023. Pre 3 March 2021 contracts are excluded, even if the expenditure is incurred after 1 April 2021.
The company must be within the charge to Corporation Tax, and the P&M must be new and not second-hand. The normal exclusions in relation to cars, assets for leasing, ships, connected party transactions, and the standard anti-avoidance provisions apply. There are special rules for the oil and gas sector.
For 130% rate assets, disposal proceeds will be taxed as a balancing charge in the disposal period and not deducted from the capital allowances pool. For disposals before 1 April 2023, the balancing charge will be based on 130% of the proceeds. For disposals in a period straddling 1 April 2023, the proceeds are time apportioned, and the 130% applied to the pre 1 April period.
For assets constructed over a period of time and partly qualifying for 130% allowances and partly under the normal rules, the proceeds are apportioned.
Disposals of 50% assets are dealt with by way of a balancing charge and apportionment, but there is no uplift.
There is the usual raft of anti-avoidance provisions in the draft legislation.
If you wish to understand whether your business would be eligible to access the new enhanced tax relief on P&M expenditure, please do not hesitate to reach out to contact one of our experts.
We use necessary cookies to make our site work. We’d also like to set optional analytics and marketing cookies. We won't set these cookies unless you choose to turn these cookies on. Using this tool will also set a cookie on your device to remember your preferences.
For more information about the cookies we use, see our Cookies page.
Please be aware:
— If you delete all your cookies you will have to update your preferences with us again.
— If you use a different device or browser you will have to tell us your preferences again.
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Analytics cookies help us to understand how visitors interact with our website by collecting and reporting information anonymously.
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.