Caravans required by the appellant’s employer to be provided by the appellant to enable him to carry out his employment duties as an assistant warden of caravan sites were not ‘plant’ for capital allowances purposes.
The appellant was employed (by CC Ltd) as an assistant warden at caravan sites. A caravan was needed by wardens and assistant wardens in most cases to fulfil their employment duties with CC Ltd. The appellant purchased a caravan in March 2010, and replaced it with another caravan in November 2011.
Following enquiries into the appellant’s tax returns for 2010/11 and 2011/12, HM Revenue and Customs (HMRC) issued closure notices amending both returns to refuse capital allowances claimed in those tax years. The appellant appealed. The main issue arising was whether the expenditure incurred on acquiring a caravan qualified for plant and machinery allowances (under CAA 2001, Pt 2).
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