Plant and machinery allowances for farming clients

Key points

• HMRC refused plant and machinery allowances for a grain silo.
• Although the facility looked like a barn it was designed specifically to dry and store grain.
• The decision in Schofield was not an authority for determining whether the facility fell within List C.
• It was critical to demonstrate a close linkage between the exterior structure of the facility and the active function of conditioning the grain.
• Writing down allowances might now be claimable for structures that have not previously been thought to qualify.
• Any claim based on the adaptation of an existing structure will require considerable care.

The appellant in May (TC6928) farmed 900 acres of predominantly arable land in north Devon and incurred expenditure on the construction of a facility variously described in evidence as a ‘grain store’ or ‘silo’. HMRC had accepted a claim for plant and machinery allowances on the free-standing equipment at the facility (principally movable ‘pedestal fans’ placed...