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Capital Allowances Act 2001

Section 143: Effect of attribution

551.This section is based on section 33C of CAA 1990. It gives effect to an attribution as a disposal value in the single ship pool.

552.This may seem a roundabout way of doing things. The shipowner has in effect already had tax relief for the expenditure on the new ship against the earlier balancing charge. So it might be thought that all that is needed is to provide that some or all of the expenditure on the new ship is not qualifying expenditure. Although that would adequately reduce future plant and machinery allowances it could also cause problems. For example, when the new ship is sold, section 62 might mean there was no disposal value. The approach here, which in effect:

  • lets the shipowner add the expenditure on the new ship to a pool but

  • requires a disposal value in the pool,

fits in better with the wider scheme of Part 2.

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