INDEPENDENT CAPITAL ALLOWANCES VALUERS

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Spring Budget 2023

Full expensing has arrived for companies, (well politicians are expert at full expensing). General pool plant and machinery (18% wda) incurred from 1 April 2023 to 31 March 2026 will attract 100% first year tax relief without any cap. For integral features (6% wda) this will attract 50% allowance in the first year with the […]

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Tax Case December 2022 Update

Court of Appeal Decision – Capital Allowances Tax Case Regarding Disputed Expenditure on the Structures of an Enrichment Plant

The Court of Appeal (Civil Division) has published its decision on the case of Urenco Chemplants Limited and Urenco UK Limited v HMRC [2002] EWCA CIV 1587.

It overturned decisions made by the Upper Tier Tribunal (UTT) […]

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GROWTH PLAN 2022: CAPITAL ALLOWANCES

Chancellor Kwasi Kwarteng announced today the following which will have implications for capital allowances:

Annual Investment Allowance (AIA)
AIA ‘permanently’ set at £1m instead of reducing to £200k. Over the next 5 years this is estimated to save Tax payers £5bn.

Corporation Tax
19% Corporation tax rate retained. By scrapping the proposed tax increase to 25% this is estimated […]

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Capital Allowances Tax Case

Capital Allowances Tax Case Regarding Disputed Expenditure on the Structures of an Enrichment Plant

URENCO CHEMPLANTS LIMITED AND URENCO UK LIMITED V HMRC [2022] UKUT 00022 (TCC)

Overview

In 2018, Urenco (The Appellant) constructed a £1bn specialist facility at Capenhurst in Cheshire, which is used for the enrichment of uranium and the “deconversion” of the radioactive, corrosive, toxic […]

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Capital Allowances and Wind Farms: Recent Case

Gunfleet Sands Limited – FTT Generates Decision

In Gunfleet Sands Limited and others v HMRC, the First Tier Tax Tribunal (FTT) considered whether Capital Allowances claimed on expenditure for studies and project management prior to the construction of the Windfarms was on the provision of plant. There were four appellant companies; who were all members […]

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Capital Allowances: Research and Development Tax Case

Recent Research and Development (R&D) Tax Case Implications for Capital Allowances Claims

Appeal Number: TC/2019/06690

Grazer Learning Limited appealed against HMRC for a tax credit enquiry amounting to £26,050 regarding expenditure incurred on R&D for the accounting period ending 31 October 2017. The £26,050 was initially accepted and paid to the Appellant on 6 June […]

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Update on BPRA Case – Upper Tier Tribunal

LONDON LUTON BPRA PROPERTY FUND LLP V THE COMMISSIONERS FOR HMRC

Following the decision reached by the First Tier Tribunal (FTT) that a significant amount of costs incurred by London Luton BPRA Property Fund LLP (Fund) to OVL (developer) ‘in connection with’ the conversion of a disused flight training centre into a hotel qualified for BPRA, […]

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