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In JRO Griffiths Ltd v HMRC [2021] TC08203, the First Tier Tribunal (FTT) found that a potato storage facility was both a silo for temporary storage and a cold store. It was plant and was eligible for capital allowances.

A person engaged in Qualifying activities can claim capital allowances on capital expenditure that qualifies as Plant and machinery if it is used in that qualifying activity.

JRO Griffiths Ltd (JRO) incurred capital expenditure of £319,483 on the construction of a warehouse to store potatoes.

The FTT allowed the appeal:

Useful guides on this topic

Plant & machinery: Allowances
What capital allowances are available on plant and machinery? How do you calculate them? What are qualifying activities?

What expenditure qualifies for plant & machinery allowances?
What is plant and machinery? What expenditure qualifies as plant and machinery? What is treated as part of a building?

What are qualifying activities for capital allowances purposes?
What activities qualify for capital allowances? What activities are excluded?

Structures & Buildings Allowance (SBA)
Who can claim Structures and Buildings allowance? What expenditure is eligible? How to make a claim?

How to appeal an HMRC decision
Disagree with a HMRC decision? How to appeal, what type of decision can you appeal and what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

Closure notices
When does HMRC issue a Closure Notice? Can a taxpayer demand one? Are there appeal rights?

External link

JRO Griffiths Ltd v HMRC [2021] TC08203


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