Capital Allowances Act 2001 section 212ZA

Apportionment of expenditure incurred partly for NI rate activity

Section 212ZA requires companies to apportion qualifying expenditure on plant or machinery between Northern Ireland rate activities and main rate activities when the asset is used for both purposes.

  • Where plant or machinery is used partly for a Northern Ireland rate activity and partly for a main rate activity, the qualifying expenditure must be split between the two on a just and reasonable basis
  • The apportionment applies specifically to annual investment allowances and first-year allowances claimed by the company
  • The expected extent of use for each activity is a key factor in determining a fair split of the expenditure
  • Where the allowance has already been reduced (for example, due to partial depreciation subsidies), it is the reduced amount that is subject to apportionment

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