CA21230 - Plant and Machinery Allowances (PMA): meaning of plant and machinery: football ground improvements

After the Taylor report made recommendations in 1990 concerning the improvement of football grounds, the Inland Revenue issued a letter to the Football League, on 25 January 1991, to indicate what expenditure was likely to qualify for PMAs. The letter listed as an appendix the sort of assets used by a football club in its trade that would normally qualify as plant or machinery. The list can be found below.

The list predates the statutory tests in CAA01/SS21-23, however, many but not all of the items listed qualify as plant under the current legislation. The rate of WDA will depend on the particular asset. As with all cases concerning the plant/premises divide and the question of whether or not an asset qualifies for PMAs the requirement is to apply the statutory tests in CAA01/SS21-23 and 33A to determine whether the asset is excluded from PMAs or treated as if it were plant; and, if neither excluded nor treated as if it were plant, to identify the particular function of the particular asset in the particular trade in order to establish whether it is plant in common law. See CA21010.

This is the list (NB the provisions referred to in items 9 and 11 were withdrawn in 2013):

  1. Advertising hoardings and perimeter boards which are not simply part of a perimeter fence or other structure
  2. Air conditioning plant, fans and ventilation machinery
  3. Automatic exit doors and gates
  4. Bicycle holders
  5. Cameras, televisions, video recorders
  6. Cars, coaches and vans
  7. Computers, printers, photocopiers, typewriters and cash registers
  8. Cookers, fridges, freezers, microwaves, dishwashing machines
  9. Crush barriers securely fixed to the ground are not plant or machinery but they may come within the 1975 safety legislation and so qualify under CAA01/S32 [withdrawn in 2013]
  10. Electric scoreboards and visual displays
  11. Fencing is not plant or machinery but it may come within the 1975 safety legislation and so qualify under CAA01/S32 [withdrawn in 2013]
  12. Fire alarm systems, fire extinguishers, sprinkler systems
  13. Floodlighting
  14. Floor coverings that are not part of the building or structure; for example, carpets (but not tiles which are stuck down)
  15. Goalposts and certain movable training equipment of a capital nature, for example, a vaulting horse (but not equipment which is part of the premises)
  16. Heating installations, boilers and water heaters
  17. Lifts and hoists
  18. Public address equipment - microphones, amplifiers and loudspeakers
  19. Racking, shelving, cupboards and furniture
  20. Telephones and telephone equipment, for example, private exchanges.
  21. Toilet sanitary ware, sinks and basins, baths and showers whether for staff or public (but not the mains water supply)
  22. Turnstiles and spectator counting equipment

The letter gave some guidance on seats. It said that most modern types of seats are likely to qualify as plant or machinery, both plain plastic tip-up seats and more luxurious types of seat. It makes it clear that seating which is no more than an integral part of the stand will not qualify.

It says that the incidental costs of installing seats, or any other type of plant or machinery, may qualify under CAA01/S25 (CA21190). It says that expenditure will not qualify as incidental if it creates an essentially new asset such as a stand or a terrace with an entirely new rake. It also says that we would not expect expenditure to qualify as incidental if it is large in proportion to the cost of the plant or machinery being installed.

Remember that not all expenditure incurred by clubs to comply with the requirements of the Football Spectators Act 1989 will qualify for capital allowances. The normal rules will apply.

The letter states that expenditure on the fabric of a police control box will not qualify for capital allowances. Since issuing the letter, we were advised that some local authorities took the view that they had the power under the Safety at Sports Grounds Act 1975 to require police control rooms to be installed. If that happened and the expenditure was incurred before 1/6 April 2013, it qualified under CAA01/S32.