Legislation: Former CAA 2001, s. 361(1)(a), Pt. 4 (agricultural buildings allowances)

Key case law:

Abbott Laboratories Ltd v Carmody (1968) 44 TC 569

Attwood v Anduff Car Wash Ltd [1997] BTC 454

HMRC material:

CA 21230

CA 22270 (fencing as a security asset)


Fencing is not considered by HMRC to qualify as plant or machinery. HMRC specifically stated this in its (strictly speaking, the Inland Revenue’s) letter to the Football League written in January 1991. Even advertising hoardings and perimeter boards will not qualify as plant if they are ‘simply part of a perimeter fence’.

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