Capital Allowances Act 2001 section 196

Disposal values in relation to fixtures: general

Section 196 sets out the rules for determining what disposal value must be brought into account when a person ceases to own a fixture or a disposal event occurs in relation to a fixture, covering twelve different types of disposal scenario.

  • The disposal value depends on the nature of the disposal event โ€” for example, sale of the qualifying interest, expiry of the interest, severance of the fixture, assignment of rights, or permanent discontinuance of the qualifying activity
  • Where a qualifying interest is sold below market value and the purchaser either cannot claim qualifying expenditure or is a connected dual resident investing company, the disposal value is based on what the market value sale price would have been
  • Where the buyer and seller jointly elect under sections 198 or 199 to fix the apportionment of the sale price or lease premium to fixtures, those elected amounts override the normal disposal value rules
  • These fixture-specific disposal value rules do not prevent other disposal values arising under the general plant and machinery rules in Chapter 5, and all disposal values under this section are subject to the anti-avoidance provisions in section 197

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