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 storage facilities and created […]

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Capital Allowances Plant and Machinery in a Civil Engineering Context Update

By : February 28, 2019 Comments Off on Capital Allowances Plant and Machinery in a Civil Engineering Context Update

UPDATE ON CASE

SSE GENERATION LIMITED V THE COMMISSIONERS FOR HMRC

HMRC TO CHALLENGE THE FIRST TIER TRIBUNAL TAX CHAMBER RULING

 

HMRC have decided to challenge the ruling given by the First Tier Tax Tribunal which they considered was largely in favour of the taxpayer.  The case is to be heard by […]

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Capital Allowances: HMRC Clutching Straws on a Grain Storage Structure

By : February 13, 2019 Comments Off on Capital Allowances: HMRC Clutching Straws on a Grain Storage Structure

HMRC clutching straws on a grain storage structure :

Stephen May and another v HMRC [2019] UKFTT 32 (TC)

 Overview 

 There has been a capital allowance case to determine whether a facility for drying, conditioning and storage of grain is a “silo provided for temporary storage” within the meaning of Capital Allowances Act […]

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Capital Allowances Plant and Machinery in a Civil Engineering Context

By : October 3, 2018 Comments Off on Capital Allowances Plant and Machinery in a Civil Engineering Context

SSE GENERATION LIMITED V THE COMMISSIONERS FOR HMRC

FIRST TIER TRIBUNAL TAX CHAMBER

 

This is the first significant capital allowances case since IRC v Barclay, Curle & Co Ltd [1969] where expenditure on capital allowances has been considered for civil engineering type expenditure.

Of particular interest is just how far […]

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Effective Dealing with HMRC for Capital Allowances

By : November 3, 2015 Comments Off on Effective Dealing with HMRC for Capital Allowances

There are 4 main areas of concern for HMRC with any Capital Allowances (CA) claim; entitlement, credibility, quantum and eligibility.

Entitlement requires careful consideration of the tax history and appropriate valuation basis. Also considerations of the nature of trade and specific expenditure.

Credibility issues can be reduced by submitting a fully detailed, cross referenced, well […]

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