Schedular System of Taxation - The Schedules - Case I of Schedule D and Schedule A - Tax Depreciation

Tax Depreciation

Since no capital deductions are allowed, depreciation on capital assets is not tax-deductible, although tax depreciation, known as "capital allowances" is available instead for expenditure on some capital assets. Capital allowances are given by the Capital Allowances Act 2001 (CAA 2001). Note that expenditure on finance leases (as opposed to, say, lease or hire purchase agreements) is considered to be revenue. Therefore interest payments and depreciation on finance leases is deductible. If the finance lessor owns the asset, however, it may be able to make a claim for capital allowances.

There are various types of capital allowances. By far the most common type of allowance is plant and machinery allowances. "Machinery" takes its normal meaning. "Plant" has no statutory definition, although the legislation does designate a few assets as plant (e.g. "integral features", expenditure on safety at sports grounds and personal security assets) and also defines what cannot be plant (called "buildings" and "structures"). Plant is defined by more than 100 years of case law. It is in essence business 'apparatus', which can in practice include many fixtures and fittings in buildings .

Plant and machinery allowances conventionally gave a 25% reducing balance basis annual 'writing down allowance' (WDA). The 25% WDA was reduced to 20% from April 2008. This means that if a plant asset, say, was bought for £400 in year 1, 20% of £400 (i.e. £80) would be deductible from taxable profits as tax depreciation in year 1. Then 20% of £(400-80) (i.e. £64) would be deductible in year 2, and so on. The 20% figure is reduced to 10% for certain 'special rate' assets. These include "integral features" (electrical systems; cold water systems; heating, hot water, ventilating and air conditioning systems; lifts, escalators and moving walkways; and external solar shading), "long-life assets" (plant and machinery with an expected life when new of 25 years or more - subject to various exemptions, i.e. assets in offices and retail shops), and the addition of thermal insulation to existing buildings. From April 2008 the first £50,000 of expenditure on plant and machinery each year may be written-off in that year (called an "Annual Investment Allowance"). There are also 100% first year capital allowances for expenditure on energy-saving and environmentally beneficial (i.e. water conserving) plant and machinery (called "Enhanced Capital Allowances").

Capital allowances were also given at 4% straight-line for expenditure on industrial and agricultural buildings. However, these allowances are being phased out by April 2011 by reducing the rate of WDA by one-quarter each year, so that broadly the rate will reduce to 3% from April 2008, 2% from April 2009, 1% from April 2010 and nothing from April 2011. Industrial buildings are those in use for various purposes including manufacturing, processing and some storage etc. They are also available for qualifying hotels (those with at least 10 letting bedrooms and meeting other conditions) and commercial buildings in specially designated areas of need, called "enterprise zones" (which qualify for a 100% initial allowance, but will also be withdrawn from April 2011).

Tax depreciation is also potentially available for expenditure on: business premises renovation (100% initial allowance), flat conversions (100% initial allowance), research and development (100% initial allowance), mineral extraction (10% or 25% WDAs), know-how (25% WDA), patents (25% WDA), dredging and assured tenancies. Expenditure on cleaning-up contaminated land and buildings may qualify for 150% "land remediation relief" and adding thermal insulation to residential properties may qualify for a "landlord's energy saving allowance", giving a £1,500 deduction per dwelling.

In particular, no tax depreciation is available for expenditure on land, abortive expenditure, expenditure which does not give rise to a capital asset, and apart from the specific circumstances mentioned above for most buildings.