Legislation: CAA 2001, s. 22 (list B, item 1), 23 (list C, item 25)

Key case law: SSE Generation Limited [2018] TC06618

HMRC material: none

Commentary

From 29 October 2018, tunnels may qualify for the structures and buildings allowance where contracts for construction, conversion or renovation works are entered into on or after 29 October 2018 and the works also commence after that date (see ¶259-000ff).

Tunnels do not qualify as plant. Together with bridges, viaducts, aqueducts, embankments and cuttings, they are classified as structures by CAA 2001, s. 22, which means that they are unable to qualify.

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