I would expect there to be anti-avoidance to cover this, but can't find anything at the moment (perhaps it's covered by GAAR?):
Let's say we're a couple of years down the line when the AIA is £25k. My company incurs qualifying expenditure of £500k, most of it at 8% pa. This means that I will need to wait years to obtain anything like a reasonable amount of relief. So, I form a new company and transfer everything across, with a consideration of £1 for plant and machinery. Result - qualifying expenditure immediately relieved in full. Sounds too good to be true, but the only anti-avoidance that I can find restricts the buyer's allowances - which would not apply in this case. So, what have I missed?