Monday, April 5, 2021

Capital Allowances - "Super Deduction"

In an effort to boost corporate capital expenditure in the coming months, the Chancellor announced a new "super deduction" for certain types of asset acquisitions. Expenditure on new assets incurred between 1 April 2021 and 31 March 2023 which would usually qualify for the writing-down allowance of 18% (up to 100% if under the Annual Investment Allowance) will be eligible for a first-year allowance of 130%. Certain types of assets are excluded from the allowance, including cars, but expenditure on computers, office furniture, commercial vehicles, and machinery will qualify. Unlike the AIA there is no limit to the amount of expenditure which can be claimed. Contrary to some initial reports, the allowance appears to only be available to companies subject to corporation tax not to unincorporated businesses.

The effect of the allowance is to provide tax relief at a rate of 24.7% which perhaps provides us with a clue as to why the allowance has been introduced and why it only applies to companies. The rate of corporation tax for larger companies rises to 25% on 1 April 2023 and, without this allowance, it might have been in the interests of such organisations to delay capital expenditure until they could obtain a 25% tax deduction rather than 19% - or am I a cynic?

There are complex rules for accounting periods which straddle 1 April 2023 and special provisions for balancing charges on assets which benefit from the allowance and are then sold before 1 April 2023 or during a period which straddles that date. Careful thought and expert advice are needed.

In conjunction with the super allowance a new 50% first-year allowance has been introduced, for the same period, applying to assets which would normally be eligible for the special allowance rate of 6%. This applies to items such as long-life assets, thermal insulation, and integral fixtures. This also looks generous but it may be more attractive to use the AIA of 100% where this is available.