The taxpayer company appealed against the disallowance by HM Revenue & Customs (HMRC) of capital allowances on the cost of constructing a building (described by the company as a ‘valeting bay’) as plant or machinery. The taxpayer supplied Renault cars, and needed to valet cars as part of its activities. This included a process of applying a finish (‘glasscoat’) to new cars at specified temperatures.
The valet building consisted of a concrete floor, walls of standard concrete block construction, and a flat roof set on wooden beams. The walls were insulated, the floor was raised, and the building had six wall-fixed heaters to provide the optimal temperatures for the glasscoat process. Planning permission had been given for a “double garage and retaining brick wall.”
The First-tier Tribunal (FTT) noted there was nothing to show that there was “anything so unique” about the building
