Fixed values

I am in the process of incorporating a trading partnership which has made significant capital allowance claims on the fixtures inherent in the premises. All assets and liabilities will be transferred in exchange for shares in the company.

I am aware of the new requirement from April 2012 of the need to fix the disposal value of the fixtures under CAA 2001 s 187A(5) if the company is to be eligible for capital allowances going forward.

However an election under CAA 2001 s 266 is being considered to transfer the fixtures (and chattels) at tax written down value (TWDV). How does this interact with the “fixed value requirement”?

CAA 2001 s 267 describes the effect of the election. It states that the relevant plant and machinery is treated as sold for a price that avoids balancing adjustments (TWDV). So we technically have a disposal...