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Contents

Official guidance
Capital Allowances Manual

CA26000 · PMA: Fixtures

  • CA26025 · Background and meaning of fixture
  • CA26050 · Scope of fixtures legislation
  • CA26100 · Meaning of relevant land, lease and interest in land
  • CA26150 · Person with interest in relevant land
  • CA26200 · Equipment lease, equipment lessor, equipment lessee
  • CA26250 · Purchaser of land giving consideration for fixture
  • CA26300 · Acquisition of land including fixture previously leased under an equipment lease
  • CA26350 · Incoming lessee
  • CA26400 · Restriction where previous PMA claim
  • CA26450 · Restriction where industrial buildings allowance or research and development allowance claimed previously
  • CA26470 · Changes in ownership: Introduction and commencement
  • CA26472 · Changes in ownership: Conditions for allowances
  • CA26474 · Changes in ownership: Past owner
  • CA26476 · Changes in ownership: Pooling requirement
  • CA26478 · Changes in ownership: fixed value requirement
  • CA26479 · Changes in ownership: Fixed value requirement: Application to tribunal
  • CA26480 · Changes in ownership: Relevant two year period
  • CA26482 · Changes in ownership: Disposal value statements
  • CA26484 · Changes in ownership: Evidence necessary to substantiate a claim
  • CA26486 · Changes in ownership: Sale of an asset that is no longer a fixture
  • CA26500 · Cessation of ownership of fixtures: qualifying interest
  • CA26525 · Cessation of ownership of fixtures - qualifying interest in special cases
  • CA26550 · Cessation of ownership: incoming lessee, severance, equipment lessor
  • CA26600 · Acquisition of ownership
  • CA26700 · Disposal values
  • CA26750 · Disposal values and avoidance cases
  • CA26800 · Election to fix apportionment
  • CA26850 · Election procedure
  • CA26900 · Definitions
  1. PMA: Fixtures: Contents
  2. PMA: Fixtures: Disposal values

CA26700 | PMA: Fixtures: Disposal values

From HM Revenue & Customs · Capital Allowances Manual

CAA01/S196

The disposal values for the various disposal events are set out below. However, the disposal value will normally be limited under CAA01/S62 to the qualifying expenditure incurred on its provision by the person bringing the disposal value to account. There is one exception to this: If the person bringing the disposal value to account acquired the asset from a connected person or in a series of transactions between connected parties, the disposal value is limited to the greatest qualifying expenditure incurred by anyone in the chain.

Disposal values

Sale of the qualifying interest at or above market value:

The part of the sale price on which the buyer can claim PMAs as expenditure on the provision of the fixture.

If the buyer cannot claim PMAs, the sale price of the fixture is that part of the sale price on which the buyer would be able to claim PMAs if a claim were possible.

Sale of the qualifying interest for less than market value:

Market value unless:

  • the buyer’s expenditure on the acquisition of the fixture qualifies for PMAs, and

  • the buyer is not a dual resident investing company (See CTM34560) that is connected with the seller.

In that case the disposal value is that part of the sale price on which the buyer can claim capital allowances as expenditure on the provision of the fixture.

Transfer of the qualifying interest other than by way of sale:

Market value.

Expiry of the qualifying interest:

Nil unless the person receives a capital sum by way of compensation or otherwise.

If the person receives a capital sum by way of compensation or otherwise by reference to the fixture, the disposal value of the fixture is that capital sum.

Premium paid by incoming lessee:

That part of the premium that is treated as expenditure by the lessee as expenditure on the provision of the fixture.

Severance of fixture:

Market value of the fixture when it is severed.

Assignment of rights by equipment lessor:

Consideration given by the assignee for the assignment.

Discharge of equipment lessee’s obligations for a capital sum:

That capital sum.

Permanent discontinuance of the qualifying activity followed by the sale of the qualifying interest:

The part of the sale price on which the buyer can claim PMAs as expenditure on the provision of the fixture.

If the buyer cannot claim PMAs, the sale price of the fixture is that part of the sale price on which the buyer would be able to claim PMAs if a claim were possible.

Permanent discontinuance of the qualifying activity followed by the demolition or destruction of the fixture:

The net amount received for the remains of the fixture plus:

  • any insurance money received in respect of the demolition or destruction, and

  • any other compensation of any description so received, so far as it consists of capital sums.

Permanent discontinuance of the qualifying activity followed by permanent loss of the fixture not by demolition or destruction:

Any insurance money received in respect of the loss and any other capital compensation.

Beginning of use of the fixture wholly or partly for purposes other than those of the qualifying activity:

Market value when the use begins.**

**Market value of a fixture is that part of the price paid for the qualifying interest, which, if the qualifying interest had been sold in the open market immediately before the event, would have been treated as expenditure by the buyer on the provision of the fixture.

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