Legislation: CAA 2001, s. 23 (list C, item 4, 18)

Key case law:

JRO Griffiths Ltd [2021] TC 08203; regarding IBAs, see Ellerker v Union Cold Storage Co. Ltd (1938) 22 TC 195 and Bestway (Holdings) Ltd v David Alexander Luff [1998] BTC 69)

HMRC material:


Cold rooms and cold stores each receive a separate mention in CAA 2001, s. 23. List C provides specifically that a cold room and a cold store are unaffected by the provisions of CAA 2001, s. 21 and 22. As such, they are to be considered on ordinary case-law principles. It follows from the above that there is nothing in the legislation to prevent cold rooms or cold stores from qualifying as plant.

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