FIRST-YEAR ALLOWANCES AND LEASING

摘要

In MJF (Trench Construction Systems Limited) v HMRC, the First Tier Tribunal (FIT) examined the meaning of leasing when making capital allowance claims. Expenditure which falls into any of the general exclusions, within s46, Capital Allowances Act 2001, will not qualify for first-year allowances (FYAs). General exclusion six in the legislation covers expenditure on the provision of plant or machinery for leasing. The company claimed FYAs on excavation support equipment which was provided to its customers. HMRC rejected the FYA claim on the basis that the expenditure was 'on the provision of plant or machinery for leasing' and so general exclusion six applied and FYAs were not due.