Capital Allowances Act 2001 section 51H

Fifth restriction: qualifying activities under common control

Section 51H restricts the annual investment allowance (AIA) where a person (other than a company) carries on two or more qualifying activities that are controlled by the same person and are related to one another, so that only a single AIA is available across all those activities.

  • Where two or more qualifying activities carried on by a non-corporate qualifying person are under common control and related to each other, only one AIA is available for all of those activities combined.
  • If all the qualifying activities are carried on by a single qualifying person, that person receives one AIA to cover the relevant expenditure across all those activities.
  • If the qualifying activities are carried on by more than one qualifying person, those persons must share a single AIA between them for the relevant expenditure.
  • The person or persons involved may allocate the single AIA across the relevant qualifying expenditure as they see fit.

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