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Planning Farm Investment

  • Writer: Isabelle Pearse
    Isabelle Pearse
  • Mar 19
  • 4 min read

How to make the most of capital allowances


As agricultural accountants, we are often asked how the various tax reliefs apply when investing in farm assets such as machinery, vehicles and buildings. Understanding how these rules operate is key to ensuring that expenditure is structured in the most tax-efficient way. This article provides an overview of the current rules and addresses some of the most common questions we encounter.


What are capital allowances?


Capital allowances provide tax relief on qualifying capital expenditure, such as vehicles and machinery, by allowing the cost to be deducted from taxable profits whilst the asset is retained on the Balance Sheet. The most common forms of relief include the Annual Investment Allowance, Writing Down Allowances and First Year Allowances. These differ from standard business expenses, which are deducted in full through the Profit and Loss Account.


The Annual Investment Allowance (AIA)


Businesses can claim a 100% tax deduction on qualifying expenditure through the AIA, up to a maximum of £1 million per year. Rather than spreading the cost of capital items over their useful life, the AIA allows tax relief to be claimed upfront in the year of purchase.


Companies may also be able to claim Full Expensing, which provides 100% upfront relief on qualifying new and unused plant and machinery without an upper expenditure limit. This relief is available to companies only and can be particularly useful for larger capital projects. Unlike the AIA, it does not apply to second-hand assets.


Property improvements vs repairs


A common question we receive from clients is how to distinguish between a repair and an improvement. This distinction is important because repairs are generally treated as a tax-deductible expense through the Profit and Loss Account, whereas improvements are capital in nature and do not usually attract immediate tax relief.


Repairs relate to expenditure incurred to restore an asset to its original condition. This can include the use of modern materials or techniques, provided the asset is not materially enhanced. Examples include repairing farm tracks or replacing worn fencing, even where more durable or contemporary materials are used, so long as the asset’s function and scale remain broadly the same.


Improvements, by contrast, enhance, extend or significantly upgrade an asset. Examples include constructing a new farm track, enlarging an existing track, or erecting a new farm building.


As always, invoicing will remain a key factor to any works being carried out.


Agricultural buildings


When constructing agricultural sheds, it is important to understand that upfront tax relief is likely to be limited on the structure itself. However, 100% relief can often be claimed on qualifying expenditure attached to the building, which include integral features such as electrical systems, cold water systems, heating and ventilation.


The structure itself may qualify for the Structures and Buildings Allowance (SBA), which currently provides relief at 3% per year on a straight-line basis.


Vehicles (including double cab trucks and cars)


For tax purposes, double cab trucks have historically been treated as plant and machinery and could qualify for the Annual Investment Allowance (AIA). However, from April 2025, most double cab pick-ups are treated as cars for capital allowance purposes. As a result, they will no longer qualify for AIA and instead fall within the capital allowances regime applicable to cars.


Cars do not qualify for AIA, meaning the cost is written down over time rather than relieved in full upfront. The rate of relief depends on CO₂ emissions. Vehicles with emissions of 50g/km or less are allocated to the main rate pool and attract writing down allowances at 18% per year, whereas those with emissions above 50g/km are allocated to the special rate pool and attract writing down allowances at 6% per year. New zero-emission cars may qualify for a 100% First Year Allowance, allowing full relief in the year of purchase.


It is important to note that the VAT treatment differs. Where a double cab pick-up has a payload exceeding one tonne, it is generally treated as a commercial vehicle for VAT purposes, meaning VAT recovery is considered under the normal VAT rules. Where there is private use, this may need to be reflected in the VAT treatment.


Single cab trucks are more likely to be treated as commercial vehicles for both capital allowances and VAT and may still qualify for AIA. However, private use must be considered, as this may restrict the amount of relief available.


Careful consideration is also required when purchasing vehicles through a company due to potential benefit-in-kind implications.


Silage clamps, slurry storage and grain stores


Expenditure on silage clamps and slurry storage facilities will generally qualify for capital allowances, as these assets are specifically recognised within List C of the Capital Allowances Act 2001 and are not treated as buildings or structures for these purposes. As such, they are capable of qualifying as plant and machinery, and relief is typically available under the AIA.


Grain stores require more careful consideration, as their treatment is determined largely by case law and whether the structure performs an active function and participates in the overall process, rather than simply providing storage. Features such as ventilation, drying or temperature control systems, together with use for temporary storage as part of a processing cycle, may support treatment as plant. The physical design, including wall configuration and specialist flooring, will also be a relevant factor.


Final points


Ultimately, careful planning around timing, classification and structure of farm investment can make a significant difference to the tax outcome. The current rules are generous, but not always straightforward, and small details often determine whether relief is available upfront or spread over many years. Plan it properly and the tax system works with you; get it wrong and it very quickly works against you.

 
 
 

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Copyright © 2024 James Biggs, Partner at Mitchells.

Registered to carry on audit work in the UK; regulated for a range of investment business activities; and authorised to carry out the reserved legal activity of non-contentious probate in England and Wales by the Institute of Chartered Accountants in England and Wales

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