Intricacies of the 2014 fixtures rules

Here is an interesting situation: I am a tax adviser to the former owners of a small hotel following a retirement sale to a new team who are refurbishing the hotel to give it a new lease of life. The purchaser’s tax advisers have asked that we sign off a ‘pooling letter’ and an election under CAA 2001 s 198. We had claimed capital allowances for the sellers but only for the loose furniture – such as tables chairs wardrobes and beds – nothing was claimed against the building fabric or things such as heating kitchen or fire alarm system. The sale agreement referenced an agreed figure for chattels land and building stock and goodwill and so I feel their proposals are rather complicated and unnecessary?

Answer

We see an awful lot of confusion around these aspects and generally little awareness of the...