In Farnell Electronic Components Ltd v HMRC (TC01440 – 13 October) a company (F) purchased large quantities of electronic components which it sold to customers in smaller quantities. It claimed industrial buildings allowances on the warehouse where the components were kept.
HMRC rejected the claim on the basis that F was carrying on a trade of distribution so that the warehouse failed to qualify for allowances. F appealed contending that it was subjecting the goods to a process.
The First-tier Tribunal rejected this contention and dismissed the appeal. Judge Walters observed that ‘the individual products are not subjected to a sufficiently substantial measure of uniformity of treatment or system of treatment to cause the system of operations conducted in the building to be a “process” in the relevant sense’.
Why it matters: CAA 2001 s 274 provided that ‘a...
