Capital Allowances Act 2001 section 339

Crown or other person not within the charge to tax entitled to the relevant interest

Section 339 deals with how qualifying expenditure on industrial buildings is written off when the relevant interest is held by the Crown or by a person who is not within the charge to tax.

• When the Crown or a non-taxable person holds the relevant interest in a building, the normal write-off rules still apply as though allowances had been properly claimed throughout
• The legislation creates a fictional taxable individual (not a company) who is treated as having held the relevant interest and carried on a trade using the building
• Any sale of the relevant interest by or on behalf of the Crown or non-taxable person is treated as connected with the termination of the fictional person's trade
• The fictional person's accounting periods are deemed to end immediately before the start of each new tax year