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Capital allowances

HMRC have taken legal steps to clampdown on plant and machinery sale-and-leaseback transactions designed to avoid tax.

The Revenue said it recently became aware of leasebacks that purported to create substantial capital allowances on assets that previously entitled the owner to no allowances.

Legislation is set to be introduced in Finance Bill 2015, with effect from 26 February 2015, to ensure an entitlement to capital allowances cannot be created by leaseback or connected party transaction when an asset is acquired without incurring expenditure.

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Ascertaining capital allowances pooling requirements on a building to be sold

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F Swain, H Swain, Clarisa Ltd (TC3896)

A Salmon (TC3789)

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