Capital allowances and partnerships

Some capital allowances are available only to companies.  Examples include the ‘super-deduction’ for expenditure between 1 April 2021 and 1 April 2023, and the ‘full expensing’ for expenditure between 1 April 2023 and 1 April 2026.

It’s been widely supposed that this means that these allowances are not available to partnerships or LLPs (which are not, of course, ‘companies’).

However, HMRC have recently revised their published guidance to make it clear that this is not the case.  Where a company is a member of a partnership, the computation of partnership profit in relation to that company should be made as though the partnership itself were a company, including ‘company-specific’ reliefs where appropriate.

This does not mean that in the case of a ‘mixed partnership’ with some corporate members and some individual members, the individual members will be able to claim these reliefs: the computation of partnership profit in relation to individual members is made using the computational rules applicable to individuals and therefore excludes ‘company-specific’ reliefs.

None of this affects Annual Investment Allowance (‘AIA’).  This continues to be available only to expenditure incurred by a ‘qualifying person’: a term which is defined by law to mean (a) an individual, (b) a partnership of which all the members are individuals or (c) a company.  Mixed or fully-corporate partnerships and LLPs are thus excluded from claiming AIA.

For more information about partnership tax implications, please get in touch with your usual BKL contact or use our enquiry form.



Sam Inkersole

In 2022, Sam won the Taxation’s Rising Star award at the Taxation Awards in and was named in the Accountancy Age 35 Under 35.

Jon Wedge

While Jon’s client work focuses on the financial services sector, he also oversees the firm’s assurance service, as well as supporting the trainees following in his footsteps.


Elana joined us in 2017 as an ACA trainee, after graduating from Durham University where she had studied languages. She is now a manager in our assurance team.


By submitting this form, the data provided will be used to perform your request according to our privacy policy.