INDEPENDENT CAPITAL ALLOWANCES SPECIALISTS

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Capital Allowances Case: Update on SSE Generation Limited v The Commissioners for HMRC

UPPER TIER TRIBUNAL TAX CHAMBER There have been a run of cases heard before the courts relating to civil and structural works, with debate about what constitutes a structure as opposed to plant.  In August 2019, the FTT heard The Cheshire Cavity Storage 1 Limited v Anor case.  This concerned a taxpayer who operates gas […]

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Underground Gas Storage Cavities & Capital Allowances

CHESHIRE CAVITY STORAGE 1 LIMITED and EDF ENERGY (GAS STORAGE HOLE HOUSE) LIMITED V HMRC [2019] FIRST TIER TRIBUNAL TAX CHAMBER (FTT) Background Both appellants were companies in the EDF Energy PLC Corporate Group and they operate gas storage facilities on adjoining site is Cheshire. The Companies used underground cavities filled with brine to store […]

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Capital Allowances – Furniture, Fixtures and Equipment Expenditure

Capital Allowances – Keeping track of accounts coded Furniture, Fixtures and Equipment expenditure – Be careful! Typically, Accountants recognise the potential to claim allowances on accounts coded Furniture, Fixtures and Equipment (FF&E). This is normally for directly paid invoices for equipment where the invoice descriptions are clear and unambiguous. These are normally identified in the […]

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Groundhog Day – HMRC Loses Appeal To Upper Tax Tribunal: Late Capital Allowances Claim

Further to our article titled ‘The Lazarus Impact – Making very Late Capital Allowances Claims’ where the First Tier Tax Tribunal allowed a pub company (the taxpayer) to file a very late capital allowances claim. HMRC appealed the First Tier Tax Tribunal’s decision at the Upper Tax Tribunal. The taxpayer won again and HMRC lost […]

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