Pillar Guide - Business Tax - 2026/27
Full Expensing 2026/27: 100% Capital Allowances for Companies
Full expensing lets companies deduct 100% of the cost of new plant and machinery immediately, with no upper limit. This guide explains how it works, how it differs from the Annual Investment Allowance, and the balancing charge that applies when you later sell the asset.
Key Facts
What Is Full Expensing?
Full expensing is a 100% first-year capital allowance for companies that invest in new plant and machinery. Introduced from 1 April 2023 as a temporary replacement for the old super-deduction, it was made permanent following the 2024 Autumn Statement. It applies only to companies within the charge to Corporation Tax, and lets the entire qualifying cost be deducted from taxable profits in the period the expenditure is incurred, rather than spread out over years through standard writing down allowances.
Full Expensing vs the Annual Investment Allowance
Full expensing and the Annual Investment Allowance (AIA) both give 100% relief, but they are not the same thing and businesses often confuse them.
- Cap: AIA is capped at £1 million a year; full expensing has no cap at all
- Who can claim: AIA is open to sole traders, partnerships and companies; full expensing is companies only
- Condition of asset: AIA covers new and second-hand assets; full expensing covers new and unused assets only
- Practical use: most companies use AIA first for spending up to £1 million, then rely on full expensing for larger capital programmes or when AIA capacity has already been used elsewhere in a group
What Qualifies
- New and unused plant and machinery that would normally go into the main rate pool (18% WDA), qualifying for the full 100% deduction
- New special rate assets, such as integral features of buildings, qualifying for a 50% first-year allowance with the remainder in the special rate pool
- Excludes cars, which follow the separate car capital allowances rules based on CO2 emissions
- Excludes assets bought for leasing out to another business, in the same way the AIA does
- Excludes second-hand assets, which must instead use the AIA or standard writing down allowances
Disposal and Balancing Charges
Because full expensing gives 100% relief immediately, the tax written-down value of the asset is treated as nil. When the asset is later sold, scrapped for value, or otherwise disposed of, the full disposal proceeds (not just the amount above written-down value) are added back to taxable profits as a balancing charge. This is different from the ordinary capital allowances pools, where disposal proceeds simply reduce the pool balance and only trigger a balancing charge if the pool itself goes negative.
For assets expected to have a meaningful resale value within a few years — vehicles used in a trade, for example, though cars themselves do not qualify — this makes it worth modelling the tax cost of a future sale before claiming full expensing, since it can claw back a large part of the relief in one go.
Worked Example
A manufacturing company buys £1.4 million of new production machinery in the 2026/27 accounting period. It uses its £1 million Annual Investment Allowance first, and claims full expensing on the remaining £400,000, giving 100% relief on the entire £1.4 million spend in the same period rather than spreading relief over many years of writing down allowances.
Four years later, the company sells the machinery for £250,000 as part of an upgrade. Because full expensing was claimed and the written-down value is nil, the entire £250,000 is added back to taxable profits as a balancing charge in the year of sale, rather than the smaller amount that would have arisen if the machinery had instead been in the ordinary capital allowances pool.
Common Pitfalls
- Assuming sole traders can claim it. Full expensing is for companies only — unincorporated businesses must rely on the Annual Investment Allowance instead.
- Claiming on second-hand assets. Full expensing is restricted to new, unused plant and machinery; second-hand purchases need the AIA or standard allowances.
- Not planning for the balancing charge. Selling an asset that received full expensing can trigger a large, unexpected tax charge on the full sale proceeds.
- Confusing it with the AIA cap. Businesses sometimes think full expensing is capped at £1 million like the AIA — it is not, which is exactly why it matters for large capital programmes.
- Forgetting the loss position. A large full expensing claim can create or increase a trading loss, which needs planning around group relief, loss carry-back or carry-forward.