Warehouse constituted plant for temporary storage

The taxpayer grew potatoes for crisps. This involved storing potatoes for long periods. To ensure the product kept well the taxpayer built a specialised storage facility which used external air at ambient temperature with no mechanical refrigeration. The taxpayer claimed capital allowances on the basis the warehouse was plant because it carried out a critical function – storing potatoes in the right condition until they were needed.

HMRC refused the claim saying the store was premises or a setting for the taxpayer’s trade and storage was not generally considered to be plant.

The taxpayer appealed.

The First-tier Tribunal decided the facility was plant. It was central to the taxpayer’s business of growing and selling potatoes to crisp manufacturers. Each item of machinery in the store functioned as part of the whole. It was not the setting for the trade but an integral part of how the taxpayer carried out its...