Capital Allowances Act 2001 section 51E

Fourth restriction: other companies under common control

Section 51E requires companies that are controlled by the same person and related to one another — but which do not fall within the group company rules in sections 51C or 51D — to share a single annual investment allowance (AIA) between them.

• Where two or more companies are controlled by the same person and are related to each other, but are not caught by the group company sharing rules in sections 51C or 51D, this section applies instead
• These commonly controlled, related companies are entitled to only one AIA between them, not one each
• The companies may decide among themselves how to allocate the single AIA across their qualifying expenditure
• The qualifying expenditure covered is that incurred by the companies in chargeable periods ending in the financial year in question