Readers’ forum: Pooling problem

01 December 2015

Issue: 4529 / Categories: Forum & Feedback

The treatment of receipts by a company for integral features in trading premises.

We act for a trading company X Ltd. In April 2015 it was sold by its sole shareholder (Mr B) to third-party investors. Immediately after sale Mr B agreed to buy the trading premises owned and occupied by the trading company and subsequently lease them back to the company under its new ownership.

The company had previously made a capital allowances claim of £20 000 on integral features in 2011. Because a balance of the annual investment allowance (AIA) was available this was claimed rather than including this amount in the special rate pool.

An election under CAA 2001 s 198 has now been signed and a value affixed to the integral features of £7 000 between both parties. There is no balance brought forward in the special rate pool but there are assets (motor vehicles and the like) in the main pool and...

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