Today's capital allowances Budget changes might sound like a giveaway with a new 40% First-Year Allowances (FYA) for all businesses (with extensions for leasing) but that 18% to 14% Writing Down Allowance (WDA) reduction for existing 'main rate' plant or machinery (P&M) means that overall HM Treasury is hoping to raise an extra £1bn to £1.5bn annually from 2026/27.

A rates mitigation scheme for 'occupation' might be effective for non-domestic rates purposes but is unlikely to withstand scrutiny for 'use' in claims for Structures and Buildings Allowances.

When presented with a tax computation for review, the most important category of expenditure that frequently reveals hidden behaviours and compliance risk is what has been treated as ineligible for a tax deduction – the ‘non-qualifying’ costs.