CA22120 - Plant and Machinery Allowances (PMA): buildings and structures: cold stores

CAA01/S23, Item 18, List C

Expenditure on the provision of a cold store is not affected by the statutory exclusions in CAA01/SS21 & 22. CA22030

The term ‘cold store’ takes its ordinary meaning. Typically ‘cold storage’ means storage and preservation of goods in refrigerating chambers.

If a building constitutes a ‘cold store’ this does not automatically mean that it will qualify for PMAs. Cold stores only qualify for PMAs to the extent that they function as ‘plant’ in common law.

It will be rare for an entire cold store building to qualify for allowances but this will depend on its nature and function.

If a building houses an insulated box and the building is capable of separate existence, then it is only the insulated box that will qualify as plant.

On the other hand, if the refrigerating elements are integrated to the extent that removal of all of them would leave only a framework which would be incapable of independent existence as a building, then the entire building might constitute plant, but only if it is first and foremost in the nature of apparatus and only secondarily a building or premises. This has to be judged in each case on the basis of a realistic appraisal of the facts. For example, a building that is essentially just a large freestanding freezer might satisfy the test. By contrast, an ordinary warehouse that happens to be kept cold would not.