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KPMG’s Capital Allowances and Tax Depreciation group is recognised as Ireland’s leading advisers on capital allowances. We are the only Big 4 firm in Ireland to have a dedicated multidisciplinary capital allowances team and we are partner lead.

For over 20 years, we have successfully prepared, negotiated and settled claims for all types of property investments for a wide cross-section of clients – from individuals and small companies to large multinationals. Our dedicated team consists of full-time chartered quantity surveyors and tax professionals who work solely on preparing fair and compliant tax depreciation / capital allowances claims for our clients.

Our experience has shown that capital allowances / tax depreciation claims are often understated, which results in taxpayers leaving behind valuable tax/cash savings. We can help rectify the situation and identify your full entitlement. The combination of extensive knowledge of the construction, property, surveying, tax and accounting fields is a unique offering in Ireland, and our unrivalled experience helps ensure our clients claim their appropriate entitlement.

Since our foundation, we have built a bespoke claim methodology, which has been tried and tested under a significant number of Revenue audits.

Benefits of claiming capital allowances

  • Claim an immediate tax benefit.
  • Make appropriate tax payments only.
  • Achieve resulting cash flow benefits.

How can KPMG help?

KPMG’s capital allowances group will carry out an initial assessment of your capital expenditure – at no cost – to determine if there is an opportunity for us to add value.

We understand that your time is a scare resource. We aim to reduce the workload of our clients by providing a tailored and streamlined process proven to allow you to claim the proper benefit with minimal disruption to your day-to-day activities. We seek to ensure that the interaction with the relevant personnel is kept to a minimum but appropriate level.

Get in touch

Contact Ken Hardy or Damien Flanagan of our Capital Allowances team if you think you may be in a position to benefit from tax depreciation/capital allowances. We would be delighted to discuss your particular circumstances or carry out an initial assessment of your capital expenditure to see if there is a potential opportunity for us to assist – this is, of course, offered to you at no cost. Alternatively, you can e-mail us via info@kpmg.ie.

We will endeavour to respond to your initial query within two working days.

Contact our Capital Allowances & Tax Depreciation team

Get our Insights

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Further information

Revenue audits

Revenue can audit a capital allowances claim for up to four years after the claim has been submitted. It is therefore important to ensure your claim is fully compliant and that there is sufficient evidence and documentation available to support your claim.

KPMG’s Tax Depreciation Group endeavours to prepare all claims on the basis that they should be expected to withstand a rigorous Revenue audit. Our team has vast experience supporting clients through Revenue audits and can provide guidance on the information required to support your claim.

See here for a list of common errors.

Implications of an incorrect claim:

  • Under-claiming: You may not have claimed the full amount of allowances / tax savings that you are entitled to. 
  • Over-claiming: If your claim is audited by Revenue, you may be leaving yourself open to repayment of the underpaid taxes relating to over-claimed allowances, in addition to interest, penalties and, in extreme cases, publication on the list of tax defaulters. 

Revenue audit FAQ

What does a capital allowances / tax depreciation audit entail?

A capital allowances audit is an examination of compliance with the relevant capital allowances legislation and consists of a thorough review of the claim from a construction, financial and tax technical perspective.

Claimants must ensure that they maintain records to back up their claim. KPMG can help ensure that you are best placed to support your claim in the event of an audit and that you have the necessary documentation in place.

How likely am I to be audited?

As a matter of course, we advise our clients that it is most likely a case of “when” not “if” your claim will be audited by Revenue.

KPMG can advise you on your capital allowances claim and on the best way to be prepared for an audit.

What should I do to be best prepared for an audit?

The best way to prepare for a Revenue audit is to make sure that your claim has been compiled in accordance with the appropriate legislation, e-briefs, tax briefings and best practice.

It is critical that you review whether the claim is likely to meet Revenue’s requirements under audit and consider whether appropriate action should be taken. In this regard, it is advisable to seek professional advice. 

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Case studies for Capital Allowances claims

What are capital allowances?

Due to the volume of claims we have prepared, our clients can be confident that our experience enables us to identify the appropriate expenditure and entitlement and prepare fair and compliant capital allowances claims. 

Case study 1

Client An Irish clothing retailer.

Project Store upgrades / fit-outs.

Claim We assisted the client with a claim of c. €600k.

Benefit The client received a tax benefit of c. €330k.

Case study 2

Client A landlord

Project Office fit-out / refurbishment including a new extensions.

Claim We assisted the client with a claim of c. €700k.

Benefit The client received a tax benefit of c. €380k

Case study 3

Client An Irish logistics service provider.

Project Depot refurbishments and upgrades.

Claim We identified c. €6m of qualifying expenditure.

Benefit The client received a tax benefit of c. €800k.

Case study 4

Client A US multinational in the medical devices industry.

Project An existing production facility and extension.

Claim We assisted the client with a successful reclassification of IBAs to plant and machinery.

Benefit The client will receive a time value saving of €1m, and a refund of c. €500k from Revenue.

Case study 5

Client An Irish manufacturing company.

Project A new production plant.

Claim We assisted the client with claims for wear and tear allowances of c. €6m and IBAs of c. €4.5m.

Benefit The client received a total tax benefit of c. €1.3m.

Case study 6

Client A private hospital group.

Project A major expansion project.

Claim We identified c. €19m of qualifying expenditure.

Benefit The client received a tax benefit of c. €2.5m.  

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Capital Allowances: Common errors & issues

Contrary to common misconceptions, claiming capital allowances is not a straightforward process. Entitlement must be established and qualifying expenditure must be properly identified. The following are some of the most common errors and issues taxpayers should be aware of.

The entitlement to claim has not been established properly.

This is a significant risk issue as it could reduce the quantum of the claim or negate it entirely. For example, taxpayers must be satisfied that they have the burden of wear and tear. Taxpayers should also pay particular attention to assets included as part of third-party agreements or finance lease agreements, as these will impact entitlement.

There is insufficient supporting documentation available to support the claim.

In the event of an audit, Revenue is likely to focus on documentation from the outset. For example, where a claim is being made on a refurbishment project, tender documents and Main Contractor Reports are typically required; invoices tend to offer insufficient evidence as they do not typically provide any description of the work undertaken.

The taxpayer has over-claimed, resulting from incorrect inclusion and/or treatment of certain types of expenditure.

Not all capital expenditure qualifies for capital allowances. For example, taxpayers should not include 100% of expenditure categorised as “Leasehold Improvements” in trial balances or financial statements as qualifying. There is no direct correlation between accounting classification of assets and their treatment for capital allowances purposes.

The taxpayer has under-claimed, resulting from the exclusion of qualifying expenditure.

The taxpayer has under-claimed, resulting from the exclusion of qualifying expenditure.

Incorrect identification of the chargeable period in which the qualifying asset has been brought into use.

Issues often arise when there is a period of testing and commissioning being carried out or where a property has only been partly brought into use.

Related issues

  • Contrary to common misconceptions, there is no approved list of assets that qualify for capital allowances. There is no legislative definition of the term “plant and machinery” or “factory”, so the identification of qualifying items is not straightforward. The meaning of P&M for tax purposes is very broad and in practice covers a vast range of items extending far beyond moveable items and fixtures and fittings. For example, “plant” often exists in the fabric of a building. Whether something is considered P&M and thereby qualifies is determined by reference to principles established in case law and Revenue practice. 
  • Capital allowances cannot be claimed in respect of grants or contributions. These need to be properly identified and treated appropriately. 
  • The amount identified as qualifying expenditure must be “incurred” and that expenditure should be identifiable in the financial statements in the relevant chargeable period. In building, refurbishment and fit-out projects that span over a number of years issues can arise where there are retention payments held.
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Capital allowances methodology

KPMG’s capital allowances group has successfully prepared, negotiated and settled capital allowances claims for all types of property investments for a wide cross-section of clients. Our extensive experience has enabled us to develop a tried and tested methodology for preparing fair and complaint claims.

As a result of our extensive Revenue experience, we would be confident that the positions adopted in our analyses would stand up to Revenue scrutiny.

Our team will undertake the following actions to prepare your claim:

Entitlement review

We will determine whether an entitlement to claim exists. This may involve a review of a purchase contract or development agreement and other supporting documentation such as the lease agreement, as necessary

Collation of construction cost information and finance information

We will liaise with the project design team, estate agents or clients' finance team to obtain the necessary construction cost information and finance information required.

Where there is no cost information available, our in-house quantity surveyors will prepare an estimate of the likely apportionment of expenditure incurred.

Site visit

We will carry out a site visit, as necessary.

Analysis of capital expenditure

We will carry out a detailed analysis of the total capital expenditure incurred to identify the maximum amount of qualifying expenditure.

Detailed preparation of report

We will prepare a detailed, standalone report to support the claim.

Audit preparation and support

We will negotiate the claim with Revenue, where required.

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Capital allowances FAQ

Who can claim?

Generally speaking, owner-occupiers, investors, landlords and lessees can claim where they’ve incurred capital expenditure for the purposes of a trade on any of the following:

  • The purchase of property – new or second-hand 
  • Construction of a new building 
  • Owner-occupier fit-out / refurbishment projects 
  • Landlord or lessee fit-out / refurbishment projects 
  • Ongoing fixed asset addition claims. 

If you built or bought a property or incurred capital expenditure on plant and machinery that is in use for the purpose of trade or rental business, you can probably claim.

Is there a list of qualifying plant and machinery / qualifying expenditure generally?

No, there is no approved list. This is a common misconception.

With regards to qualifying expenditure for Wear and Tear Allowances, there is no legislative definition of the term, “plant and machinery”, so the identification of qualifying items is not straightforward.

How is qualifying plant and machinery (‘P&M’) identified?

Plant and machinery (‘P&M’) must be identified on a first principles basis. Whether an item qualifies must be determined by reference to the facts, the nature of the trade, and the function of the item in the trade. A number of conditions/tests must be satisfied.

Do all fixed assets additions qualify for capital allowances?

No, all capital expenditure does not qualify for capital allowances.

What does entitlement mean?

A taxpayer must satisfy the relevant criteria in the legislation in order to be eligible to make a claim. We will establish that the taxpayer has an entitlement to claim and once this is confirmed, we will prepare a fair and compliant capital allowances claim.

Can landlords claim capital allowances?

Generally yes, where the property is let. It is, however, critical to establish entitlement, especially in a landlord/lessee situation.

Can property developers claim capital allowances?

Yes, when they put the property or P&M in use for the purposes of a trade or rental business.

I bought / built / refurbished a property a number of years ago, but I have not claimed capital allowances (or may have under-claimed). Can I claim the allowances now?

Depending on the facts and circumstances, you may be able to go back four years to amend your tax return to include the allowances that you should have claimed.

I don’t have any information relating to the expenditure incurred. Can I still make a claim?

We can assist by way of generating a breakdown of the expenditure once there is evidence to prove that the expenditure was in fact incurred.

What happens to the allowances that I don’t use?

Depending on facts and circumstances, unused wear and tear allowances and industrial buildings allowances can be carried forward indefinitely and used to shelter future liabilities, i.e. they will not be lost.

Are there any time restrictions for making a claim?

Depending on the specific circumstances of each case, different time limits and restrictions can apply when claiming capital allowances.

Please contact us to discuss your particular circumstances and the appropriate timing for making a claim. We can also determine whether you are in a position to make a look back claim for previous accounting periods. This is offered at no cost or commitment from you.

What are the implications of making an incorrect claim?

  • Under-claiming: You may not have claimed the full amount of allowances / tax savings to which you are entitled 
  • Over-claiming: If your claim is audited by Revenue, you may be leaving yourself open to repayment of the underpaid taxes relating to over-claimed allowances, in addition to interest, penalties and, in extreme cases, publication on the list of tax defaulters.