½Û×ÓÊÓƵ

Where the participants in a co-ownership authorised contractual scheme (CoACS — see D8.146) together carry on a qualifying activity, each participant is treated for the purposes of the structures and buildings allowance (SBA) as carrying on the activity to the extent that the profits or gains arising to him from the activity are chargeable to tax (or would be chargeable if there were any profits)¹. In determining whether or to what extent the participants are together carrying on a qualifying activity, it must be assumed that profits or gains arising to all the participants from the activity are chargeable to tax (or would be if there were any)².

The operator of a CoACS may, however, make an election under which it will calculate SBA on the basis that it carries on the qualifying activity itself and then allocate a proportion of the allowance to each participant³. If an equivalent election in respect of plant and machinery under the provisions at B3.354B has been made