S May and others v HMRC

Cathya Djanogly

In S May and others v HMRC [2019] UKFTT 32 (10 January 2019) the FTT found that a grain storage facility qualified for capital allowances (CAA 2001).

Mr May carried on a business of grain production for sale to local farms and feed mills. He had built a facility for drying and conditioning the grain once it was harvested and for storing it until it was sold. The issue was whether the facility qualified for plant and machinery capital allowances as a ‘silo provided for temporary storage’ within the meaning of s 23 list C so that it did not fall under the exclusion for buildings.

As the legislation does not include a definition of ‘silo’ the FTT turned to the Shorter Oxford English Dictionary according to which a ‘silo’ is either a pit or an underground chamber or a cylindrical tower built above ground and...

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