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Spotlight on fixtures

13 November 2012 / Ray Chidell
Issue: 4379 / Categories: Comment & Analysis , Capital Gains
RAY CHIDELL considers the technicalities and practical implications for both sellers and buyers of capital allowances changes

KEY POINTS

  • Changes from April 2012.
  • Pooling requirement.
  • Valuation and the role of the tribunal.
  • Assets for which no claim has been made.
  • Buyer needs to know what has been claimed.

New capital allowances rules for fixtures were introduced from April this year but are subject to transitional provisions until April 2014.

The nature of the rules is such that tax planning in relation to commercial property transactions needs to be completely re-evaluated.

In this article I will begin with a brief reminder of what exactly is changing. I will then consider the new rules from the perspective of seller and buyer in turn with a particular focus on the two-year transitional period that began in April this year.

The new rules are entirely concerned with “fixtures” in their...

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