Full Expensing
Full Expensing gives UK Limited Companies (and corporate partners within the charge to Corporation Tax) a 100% first-year allowance on qualifying NEW + UNUSED main-rate plant & machinery + a 50% first-year allowance on special-rate plant & machinery (e.g. integral features). The relief was introduced for capital expenditure on/after 1 April 2023 and made PERMANENT in the Autumn Statement 2023, replacing the temporary 130% super-deduction. Unincorporated businesses (sole traders + partnerships) CANNOT claim Full Expensing, they get the same 100% effect via Annual Investment Allowance up to £1m/year. The asset must be new + unused at acquisition (second-hand excluded); cars are excluded entirely; assets provided for leasing are excluded (though hire purchase generally qualifies).
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What this relief is, in plain English
Full Expensing is the headline capital allowance for Limited Companies in the UK from April 2023 onwards. It gives a 100% first-year deduction against Corporation Tax for new + unused plant + machinery purchased for the trade, no waiting, no spreading over years, no balancing acts. The 50% sister-rate for special-rate assets (integral features like electrical systems, lighting, heating/cooling, long-life assets) gives half the cost as an immediate deduction + the remainder enters the special rate pool at 6% Writing Down Allowance. The relief was originally announced as a temporary 3-year measure in Spring Budget 2023 (replacing the super-deduction that ended 31 March 2023), then made PERMANENT in Autumn Statement 2023. It's now treated as a permanent feature of the UK's capital allowances regime alongside Annual Investment Allowance (which sole traders + partnerships claim instead).
How it works
100% FYA on main-rate plant & machinery
A Limited Company purchasing NEW + UNUSED main-rate plant + machinery for its trade can deduct 100% of the cost against Corporation Tax in the year of acquisition. No carry-forward, no spreading, the whole cost reduces taxable profits in year 1. At 25% main rate CT, every £100,000 of qualifying spend reduces the tax bill by £25,000. Main-rate plant + machinery covers most loose plant: manufacturing machinery, IT hardware, office furniture, vehicles other than cars (commercial vans + lorries qualify), tools + equipment, capital software.
50% FYA on special-rate plant & machinery
Special-rate assets (integral features in buildings: electrical systems, lighting, heating + cooling, hot/cold water systems; long-life assets ≥25 years; thermal insulation) get a 50% first-year deduction + the remaining 50% enters the special rate pool at 6% WDA going forward. Effectively a 'half-Full-Expensing' for assets that historically got slower relief. A £100,000 special-rate purchase deducts £50,000 in year 1 + the remaining £50,000 attracts 6% × £50,000 = £3,000/year on a reducing balance basis.
Strict qualifying conditions, new + unused, no cars, no leasing
Three critical exclusions narrow the scope: (1) **New + unused** at acquisition, second-hand assets fall back on AIA + WDA. (2) **Not a car** of any CO₂ level, cars are explicitly excluded from both Full Expensing + AIA; the only 100% route on cars is the EV First-Year Allowance under CAA 2001 s.45D for new zero-emission cars. (3) **Not provided for leasing**: operating-lease assets are excluded; hire purchase generally qualifies. Plus: must be for a qualifying trade within UK Corporation Tax; the asset must be put to qualifying use within a reasonable time of acquisition.
Disposal creates a balancing charge
When a Full-Expensed asset is later sold or scrapped, the disposal proceeds are taxed as a 'balancing charge', added to taxable trading profits in the year of disposal. This contrasts with AIA-claimed assets, where disposal proceeds typically reduce the main pool (less immediate tax). Plan disposal timing: a full-expensed asset sold for £100,000 creates £100,000 of additional taxable profit in that year, taxed at the company's CT rate. For ongoing trading, this typically doesn't matter, the cash from sale funds new capex which gets its own Full Expensing.
Who qualifies
- Company subject to UK Corporation Tax (Limited Company or corporate partner, sole traders excluded)
- Capital expenditure on/after 1 April 2023 (transitional rules for periods straddling this date)
- Asset is NEW + UNUSED at the time of acquisition (second-hand excluded)
- Asset is plant + machinery for a qualifying trade, NOT a car of any CO₂ level
- Asset is NOT provided for leasing (operating-lease assets excluded; hire purchase generally qualifies)
- Asset is put to qualifying use within a reasonable period of acquisition (the 'in use' test)
- Expenditure not already claimed under another scheme (no double-claiming with AIA, R&D, EV FYA on the same expenditure)
Interactions with other reliefs
Annual Investment Allowance (AIA, £1m/year)
AIA + Full Expensing cover similar ground but with different rules. For Ltd Cos with qualifying new + unused plant, Full Expensing is preferred (uncapped). AIA's value is for SECOND-HAND assets, integral features (special-rate items above the 50% FYA cap-portion), and as a fallback when items don't qualify for Full Expensing. Sole traders + partnerships use AIA only; Full Expensing isn't available to them.
Writing Down Allowances (main pool 18%, special pool 6%)
Disposals from a Full-Expensed asset create a balancing charge (proceeds taxed in full); disposals from main pool reduce the pool by proceeds. **Important April 2026 change:** Main pool WDA rate reduces from 18% to 14% from 1 April 2026, increasing the relative value of Full Expensing for assets purchased BEFORE that date.
EV First-Year Allowance (CAA 2001 s.45D)
Cars are excluded from Full Expensing. New zero-emission cars (fully electric or hydrogen) qualify for 100% FYA under the separate s.45D EV regime, extended to 31 March 2027 (CT) / 5 April 2027 (IT). Used EVs do NOT qualify, they go in main pool at 18% (reducing to 14% from April 2026). EV charging point installation also qualifies under separate provisions on the same April 2027 deadline.
R&D Tax Credits (Merged Scheme)
Capital expenditure can sometimes qualify for both Full Expensing AND inclusion in R&D-qualifying expenditure if used in R&D activities. However, no double-claiming of the same expenditure across two reliefs. Most companies claim Full Expensing on the capital cost + R&D Tax Credits on the labour + consumables of using the equipment in R&D, different cost bases, different reliefs, both claimable.
Common mistakes + audit triggers
- Sole trader / partnership attempting to claim Full Expensing (only Ltd Cos + corporate partners qualify, use AIA instead)
- Claiming Full Expensing on second-hand machinery (excluded, use AIA up to £1m cap)
- Claiming Full Expensing on a car (cars excluded entirely, only EV FYA under s.45D applies to new zero-emission cars)
- Claiming Full Expensing on operating-lease assets (excluded, lessor claims relief instead)
- Failing to claim balancing charge on disposal (creates HMRC enquiry risk + interest on undeclared profit)
- Treating integral features as main-rate (incorrect, they get 50% FYA + 50% to special rate pool, not 100%)
- Confusing temporary super-deduction (ended 31 March 2023) with permanent Full Expensing (replaced it from 1 April 2023) in old advice + outdated guides
Worked example
Adaeze, Sheffield - Ltd Co director running a precision engineering business (2025/26)
Adaeze's Sheffield Ltd Co specialises in precision-machined components for aerospace. In 2025/26 she invests in new manufacturing capacity: a new £180,000 CNC machine (main-rate plant), £45,000 of new integral lighting + ventilation for the new bay (special-rate), and £24,000 of new office IT for the expanded team (main-rate). All assets are new + unused at acquisition + put into qualifying trade use within 3 months. The company is paying main-rate Corporation Tax (25%) on profits of around £500,000.
Calculation: **Step 1: Categorise the assets.** - CNC machine £180,000, NEW main-rate plant, Full Expensing 100% - Office IT £24,000: NEW main-rate plant, Full Expensing 100% - Lighting + ventilation £45,000, NEW special-rate (integral features), 50% FYA + 50% to special rate pool **Step 2: Calculate year-1 deductions.** - CNC machine: 100% × £180,000 = £180,000 immediate deduction - Office IT: 100% × £24,000 = £24,000 immediate deduction - Integral features: 50% × £45,000 = £22,500 immediate deduction; remaining £22,500 enters special rate pool at 6% WDA → £1,350 additional WDA deduction - **Total year-1 capital allowances: £227,850** **Step 3: Tax impact.** - £227,850 reduces taxable profit by that amount - Corporation Tax saving at 25% main rate: 0.25 × £227,850 = **£56,962.50** - Net cost of £249,000 capex after tax relief: £249,000 - £56,962.50 = £192,037.50 (a 23% effective subsidy on the gross investment) **Step 4: Forward-year mechanics.** - The £22,500 in the special rate pool attracts 6% WDA each year going forward (reducing balance basis). Year 2: £1,350; year 3: £1,269; year 4: £1,193... slowly tailing off. - The main-rate-Full-Expensed assets (CNC + IT) have no further allowances, they're fully relieved. On future disposal, proceeds create a balancing charge at that year's CT rate. **Sole trader comparison:** If Adaeze were a sole trader, the same £249,000 capex would have used £249,000 of her £1m AIA cap, giving the same 100% relief on the £224,000 of qualifying spend (the £45,000 integral features still get only £22,500 immediate via the 50% AIA rule). Full Expensing for Ltd Cos vs AIA for sole traders gives nearly identical economics under the £1m cap, the real Full Expensing advantage shows above £1m/year capex.
Statute reference: Finance (No. 2) Act 2023 + Capital Allowances Act 2001 (as amended) F(No.2)A 2023 ss.7-12; CAA 2001 Chapter 16ZA. HMRC manual: CA23165 (full expensing); CA23166 (50% FYA special rate).
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
I'm a sole trader, can I claim Full Expensing?+
I'm buying a second-hand industrial machine for my Ltd Co, does Full Expensing apply?+
I'm leasing equipment via operating lease, can I still claim Full Expensing?+
What's the practical difference between Full Expensing and AIA for a Ltd Co?+
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