Individual treatment

The appellant company was a member of the Premier Farnell group. It bought and sold electronic components from a warehouse that had been built in the early 1990s.

The business claimed the operations carried out in the building amounted to the subjection of goods to a process which meant the premises qualified for industrial buildings allowance under CAA 1990 s 18.

HMRC disagreed saying goods were moved from one part of the warehouse to another or prepared for sale.

The company appealed.

The First-tier Tribunal concluded the appellant’s trade consisted in the purchase and sale of goods by way of distribution not in the operations carried out in the building. The activities undertaken related to the purchase and sale of goods.

There was no uniformity of treatment of the goods because each product was dealt with according to...