Legislation: CAA 2001, s. 23 (list C, item 12)

Key case law: Carr v Sayer [1992] BTC 286

HMRC material: CA 22030


Safes are specifically not caught by table 1 of CAA 2001, s. 21 and 22 – see list C, item 12. As such, there is no statutory reason why a safe should not qualify as plant. It follows that it must be considered on ordinary case law principles.

The Carr v Sayer case, concerned with the tax treatment of dog kennels, contained the following observation by Sir Donald Nicholls:

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