Q&A: super deduction and pre-trading expenditure

In this week’s Q&A, Croner Taxwise tax adviser Tom Butt, considers whether there are limits on the type of plant and machinery investments eligible for the super-deduction tax relief

My client is undertaking preparations to trade, but due to the scale of the operation will not commence trading until April 2023. A large amount of expenditure is being incurred now on main pool items of plant and machinery. Is this expenditure eligible for the super-deduction?

The super-deduction was introduced by section 9 Finance Act 2021 allowing a 130% deduction for qualifying expenditure by companies. HMRC’s guidance is at CA23161.

This measure was designed to boost the economy by encouraging companies to invest in plant and machinery, and compensate for the increase in/reintroduction of the main rate of corporation tax rate from 1 April 2023 (25%).

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