Capital Allowances Act 2001 section 144

Amounts which cease to be attributable

Section 144 deals with what happens when a deferred balancing charge amount can no longer be matched against qualifying expenditure on new shipping, requiring a retrospective reduction in the deferment.

• Applies where a shipowner has deferred a balancing charge under section 135 and some or all of the deferred amount can no longer be attributed to new shipping expenditure
• The shipowner is treated retrospectively as never having been entitled to defer the portion that has ceased to be attributable
• An amount is considered "attributable" if it can still be matched to expenditure on new shipping under section 140
• This may arise either during or at the end of the six-year attribution period where insufficient qualifying expenditure materialises