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13 May 2014
Rogate Services Ltd (TC3449)
The taxpayer company operated a Renault franchise and valeted cars, which included the application of glass coat finishes.
The business constructed a valeting bay used solely for the application of glass coat, although it could also be used for storage.
The taxpayer said the bay was plant and claimed capital allowances on the expenditure.
HMRC refused on the ground the bay was not plant.
The First-tier Tribunal concluded the bay was a place of work where glass coat could be applied “advantageously” – meaning it was not plant.
Even if the bay were plant, it would be excluded from being so because it was a building or a structure for the purpose of CAA 2001, s 21 or s 22.
The taxpayer’s appeal was dismissed.
