»Ê¹ÚÌåÓýapp

Budget 2007 announced a business tax reform package including the gradual withdrawal of IBAs and ABAs over four years. Legislation was introduced in FA08 to give effect to those changes. »Ê¹ÚÌåÓýapp phased withdrawal of IBA writing down allowances had effect for chargeable periods ending on or after 1 April 2008 for businesses within the charge to CT and 6 April 2008 for businesses within the charge to IT. »Ê¹ÚÌåÓýappre are no IBA writing down allowances for the financial year beginning on 1 April 2011 and subsequent years.

»Ê¹ÚÌåÓýapp legislation that lets you disregard a percentage of non-qualifying use applies to an individual building. It does not apply to a collection of buildings on the same site even if taken together they form composite premises for a business (Abbott Laboratories Ltd. v Carmody 44TC569). Abbott Laboratories developed a site for their trade of manufacturing pharmaceutical products. »Ê¹ÚÌåÓýappy claimed IBA on the administration block that was connected to the pharmaceutical block, 25 yards away, by a covered passageway on the grounds that the IBA legislation let them treat all the buildings on the site as a single building. »Ê¹ÚÌåÓýapp company lost because it was held that the administration block was not sufficiently integrated with the other blocks to justify treatment of the complex of buildings as a single building.

You should treat two buildings that are linked by an overhead bridge or a covered corridor as separate buildings if the link can be easily removed. »Ê¹ÚÌåÓýapp question of whether premises constitute a single building is a question of fact and so if there is a dispute you may find visiting the premises worthwhile. You may also find the following questions helpful:

• are there common water supplies, power supply, heating system etc. If there are this is in favour of there being one unified structure
• can a part be demolished without seriously damaging the other parts. If the answer is ‘noâ€� this is evidence in favour of there being one unified structure.

»Ê¹ÚÌåÓýapp question of what is a unified structure was considered in Lancashire Electric Power Company v Wilkinson 28TC427. In that case the power house of an electricity generating station was held to be a single industrial building.