In the context of considering the sale of an FHL property it is important to remember the need to make an apportionment as between the freehold and leasehold property which is subject to CGT and the fixtures and fittings and plant and machinery which will be dealt with within the capital allowances regime for income tax or corporation tax purposes. However, a claim for capital allowances on fixtures in the property (including integral features) does not reduce the base cost of the property when calculating a capital gain (TCGA 1992, s. 41(1)), though a fixtures claim may reduce the amount of any capital loss.

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