News

SUPREME COURT RULING

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, Scotland and had […]

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 […]

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) […]

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 […]

Reforming the UK’s Capital Allowance System

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. The abolishment […]

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 […]

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 […]