S185 CAA 2001 disposal value - group of companies

[Trevor McDonald]

A capital allowances review has shown that value apportioned to fixtures and fittings for a transaction between corporate entities within a group may be understated. My client would like to increase the value given to F&F and increase the CA claim.

I am considering whether S185 would prevent this - the vendor has likely claimed capital allowances on the assets and so S185 would restrict the value entering the purchaser's pool to the disposal value/cost in the vendor's pool. So can we overcome this by also uplifting the disposal value in the vendor's pool, since it is within time limits to amend?