CA21150 - Plant and Machinery Allowances (PMA): meaning of plant and machinery: completeness test

For expenditure incurred on or after 1 April 2008 (CT) or on or after 6 April 2008 (IT) see the guidance on integral features starting at CA22300.

Another test that is sometimes applied in deciding whether an item is plant in common law is the ‘completeness test’. You apply the ‘completeness test’ to an asset in a building by considering whether the building would be complete for the carrying on of the activity that is to be carried on within it without that item. It is the same test as the third of the four general factors Hoffman said should be considered CA21140 in deciding whether an item has become part of the premises.

The ‘completeness’ test was considered by the House of Lords in the case of Cole Brothers Ltd. v Phillips 55TC188 (a case about electricity systems). In that case Vinelott, J said that he considered the ‘completeness’ test to be implicit in the J Lyons case where Uthwatt J drew a distinction between lighting which was added to a building which was otherwise complete to be used for its intended purpose and lighting which was needed to make a building complete for its intended purpose.

Cole Brothers Ltd. predates the statutory exclusions now in CAA01/SS21 & 22 and the rules relating to integral features now in CAA01/S33A. Under the current rules, certain integral features such as electricity systems (including lighting systems) are always treated as if they were plant, regardless of their function, see CA22300, and other assets that are incorporated, or of a kind ordinarily incorporated, in buildings are generally excluded under CAA01/S21, see CA21010. Therefore it is less likely today that you will need to consider the ‘completeness’ test, although it might still be relevant in some circumstances, for example, in relation to gas and sewerage systems.