CA21170 - PMA: Meaning of plant & machinery: Mains services overview

The "completeness test” CA21150 does not let you refuse all claims that electrical installations or cold water, gas or sewerage systems qualify for capital allowances as plant or machinery. In Cole Brothers Ltd. v Phillips 55TC188 Oliver L J said this. " A building may be incomplete without some form of electrical installation but if the occupier installs a system specially adapted for the particular purpose for which he intends to use the building the fact that the building would be incomplete if the electrical system were to be removed does not prevent the electrical system being plant".

The first question you should consider when you get a capital allowance claim on an electrical system or other mains service is whether you should consider the installation as a whole - the entity approach - or whether you should adopt a piecemeal approach and consider the individual parts of the system.

In the case of Cole Brothers Ltd. v Phillips 55TC188 the company claimed that the electrical installation in a new retail store should be treated as a single item of plant. The Inspector adopted a piecemeal approach by looking at the individual components of the electrical installation separately and the Special Commissioners and the Courts took the same line.