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Rogate Services v HMRC

In Rogate Services v HMRC (TC03449 – 25 March 2014) the FTT held that a car valeting bay was not ‘plant’ for the purpose of the capital allowances legislation (CAA 2001 ss 21–23).

Rogate operated a Renault franchise and its main activity was the sale of new and second-hand cars. As part of its trade Rogate carried on the specialist activity of applying wax to new cars in a valeting bay (the ‘building’) at temperatures ranging between 60 and 70 degrees Fahrenheit. Rogate appealed against HMRC’s decision to disallow the cost of construction of the building. It was accepted that Rogate carried on a ‘qualifying activity’; the issue was therefore whether the valeting bay could constitute ‘plant’ under CAA 2001.

Referring to Barclay Curle & Co (1969) 45 TC 221 the FTT noted that the building did not perform a function (like the raising and lowering...

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