COMMISSIONERS FOR HMRC V SSE GENERATION LTD
This case is an intriguing example of how a long running dispute is appealed and taken before the different stages of the Courts of Law to establish how to apply the legislation correctly.
Between 2006 and 2009, SSE Generation Limited constructed a hydro-electric power station in Gledoe, […]
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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 […]
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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 […]
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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% […]
Overview
The Government has recently conveyed their motive to bring further reform to UK Capital Allowances (CAs) as the super-deduction scheme is set to come to an end in March 2023. The general aim of this reform is to assist UK business investment and promote economic growth within the UK following the pandemic slump. […]
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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, […]
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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 […]
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UPDATE ON LAND REMEDIATION RELIEF CASE
UPPER TIER TRIBUNAL – 21st JULY 2021
NORTHERN GAS NETWORKS LTD V THE COMMISSIONERS FOR HMRC
Following the decision reached by the First Tier Tribunal (FTT) where they agreed with HMRC’s decision to refuse a claim for land remediation relief, the case was appealed by […]
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Rishi Sunak has announced a welcome extension of the Annual Investment Allowance (AIA). The Annual Investment Allowance was due to reduce from £1m to £200k from 1 January 2022. However, the £1m amount has now been extended until 31 March 2023.
In addition, the Freeport sites Humber, Teeside and Thames Freeport will be designed […]
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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 […]
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