A facility for the purposes of drying, conditioning, and storing grain constituted a ‘silo provided for temporary storage’ and expenditure on its construction qualified as plant and machinery for capital allowances purposes. 
 
In 2010, the appellant set up a new business, a large part of which involved grain production for sale to local farms and feed mills. The appellant required a facility for drying and conditioning the grain that he grew after it had been harvested, and for storing the grain until it was sold. He had this facility constructed. 
 
In his self-assessment returns for the tax years 2011/12 to 2013/14, the appellant claimed plant and machinery allowances in respect of the expenditure incurred on the construction of the facility.  
 
HM Revenue and Customs (HMRC) subsequently opened enquiries into the appellant’s returns. HMRC concluded that although