Part 2 Plant and machinery allowances
Chapter 5 Allowances and charges
Available qualifying expenditure
59 Unrelieved qualifying expenditure
(1)
A person has unrelieved qualifying expenditure to carry forward from a chargeable period if for that period—
(b)
where section 56A(2) applies, the person does not claim a writing-down allowance of the amount by which AQE exceeds TDR.
(2)
The amount of the unrelieved qualifying expenditure is—
(a)
the excess less the writing-down allowance made for the period, or
(b)
if no writing-down allowance is claimed for the period, the excess.
(3)
No amount may be carried forward as unrelieved qualifying expenditure from the final chargeable period.
F3(4)
If a person carrying on a trade, profession or vocation enters the cash basis for a tax year, no amount may be carried forward as unrelieved qualifying expenditure from the chargeable period ending with the basis period for the previous tax year.
(5)
But subsection (4) does not apply to unrelieved qualifying expenditure incurred on the provision of a car.
(6)
Where a person has unrelieved qualifying expenditure to carry forward from a chargeable period that is not expenditure allocated to a single asset pool, the amount of unrelieved qualifying expenditure incurred on the provision of a car is to be determined on such basis as is just and reasonable in all the circumstances.
(7)
Section 240B of ITTOIA 2005 (meaning of “entering the cash basis”) applies for the purposes of this section as it applies for the purposes of Chapter 17A of Part 2 of that Act.
F4(8)
Subsection (9) applies if—
(a)
a person carrying on a trade, profession or vocation incurs expenditure in relation to a vehicle,
(b)
at the end of the basis period for a tax year, the person has unrelieved qualifying expenditure incurred in relation to the vehicle to carry forward from the chargeable period ending with that basis period (“the relevant chargeable period”),
(c)
in calculating the profits of a trade, profession or vocation of a person for the following tax year, a deduction is made under section 94D of ITTOIA 2005 in respect of expenditure incurred in relation to the vehicle, and
(d)
the person does not enter the cash basis for that tax year.
(9)
None of the unrelieved qualifying expenditure incurred in relation to the vehicle may be carried forward as unrelieved qualifying expenditure from the relevant chargeable period.
(10)
Where a person has unrelieved qualifying expenditure to carry forward from a chargeable period that is not expenditure allocated to a single asset pool, the amount of the unrelieved qualifying expenditure incurred in relation to the vehicle is to be determined on such basis as is just and reasonable in all the circumstances.