Special Rate Allowance

UK Budget 2021: First Year Capital Allowances – the Super Deduction & the Special Rate Allowance

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As part of the Budget 2021, the Chancellor, Rishi Sunak, has provided for two temporary first-year capital allowances: (i) the Super Deduction and (ii) the Special Rate allowance, to apply over the next two years to boost investment and productivity levels in the UK economy.


For expenditure incurred between 1st April 2021 and 31st March 2023, companies can claim a Super Deduction in the form of a first-year relief of 130% on new plant and machinery fixed assets.  This Super Deduction will apply to capital expenditure on “main pool” plant and machinery incurred by companies between 1st April 2021 and 31st March 2023, i.e. on plant and machinery that would usually qualify for 18% writing down allowances on a reducing balance basis.  Remember, the Super Deduction is only for companies and cannot be claimed by sole traders or in professional partnerships.


Also, it is not available for items with a long life i.e. more than 25 years, or integral features within a building, or solar panels otherwise known as special rate pool items.


In summary, if a company spends £10,000 on qualifying items of plant and machinery within the specified timeframe, it will be able to reduce its taxable profits by £13,000.  It is important to keep in mind that currently the company may be in a position to claim a 100% deduction using the Annual Investment Allowance, therefore, by availing of the Super Deduction Allowance the company will receive an additional benefit of 30% of the qualifying expenditure.


Examples of what might qualify include:

  • Tractors, lorries and vans (not cars).
  • Furniture and machinery
  • Computers, laptops and printers
  • Cranes, drills, ladders, etc.


The Special Rate allowance provides relief at 50% of the qualifying cost in the first year.  The balance then returns to the normal special rate pool to be written down at the usual 6% rate on a reducing balance basis in future years.


The ‘SR allowance’ covers new plant and machinery including integral features in a building and long life assets.    Special rate expenditure broadly includes the following:

  • Lifts, escalators and moving walkways
  • Air-conditioning and air-cooling systems
  • Electrical systems, including lighting


The following restrictions, however, apply:

  • It is only available to companies within the charge to corporation tax.
  • It is not available for motor vehicles.
  • The items must be new and not second hand.
  • The items should not be used in a leasing trade.
  • the expenditure must be incurred between 1st April 2021 and 31st March 2023.


The £1 million rate of the Annual Investment Allowance will be extended to 31st December 2021.  From 1st January 2022, however,  it is expected to revert to the previous limit of £200,000.  This allowance provides relief of 100% on expenditure qualifying for capital allowances in the tax year of assessment in which the expenditure is actually incurred.


It is important to keep in mind that a company cannot claim the Annual Investment Allowance as well as the Super Deduction on the same amount of qualifying expenditure.  The Annual Investment Allowance should be considered in situations where the Super Deduction is not available including the following three scenarios:

  1. in contracts completed before 3rd March 2021 or
  2. expenditure incurred before 1st April 2021 or
  3. certain used or second hand assets purchased.


For all companies in a position to claim it, the Super Deduction will be more financially beneficial than claiming the Annual Investment Allowance with regard to main pool asset purchases.


For smaller companies it may be beneficial to claim the Annual Investment Allowance rather than the Special Rate Allowance on relevant assets, except where the total expenditure incurred on special rate pool assets exceeds the threshold amount of £1m.


Unlike the Annual Investment Allowance, there is no limit on the amount of capital investment that can qualify for either (i) the Super Deduction or (ii) the Special Rate allowance.  Therefore, there are clear incentives for businesses to bring forward their investment plans to take advantage of these first year allowances.


When an asset on which a Super Deduction or Special Rate Allowance was claimed is disposed of, the consideration will be subject to a balancing charge.  In other words, as the first year allowances are not pooled for capital allowances purposes, the proceeds from the disposal of relevant qualifying assets will be treated as taxable income.


If the disposal of the assets, on which a Super Deduction was previously claimed, occurs in a chargeable period that ends on or before 31st March 2023, the balancing charge will be equal to the disposal value multiplied by the relevant factor of 1.3 i.e. 130% of the sales proceeds.  If, however, the disposal occurs on or after 1st April 2023 then the balancing charge will equal the actual sales consideration.


If the chargeable period straddles 1st April 2023 (i.e. where a chargeable period commences before 1 April 2023 and the disposal takes place after 1 April 2023) then the relevant factor is apportioned based on the number of days before 1st April 2023.


Similar rules apply to the 50% Special Rate Allowance.


Finally, if the full deduction cannot be used by the business for offset against its taxable profits then an allowable loss will be generated.  This can:

  1. be carried forward or back under the new temporary three year loss carry back rules.
  2. It is also possible for the balance to form part of the main pool to be carried forward to future years.