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

By : Julie Davies February 16, 2021 No Comments

PLANT AND MACHINERY IN A CIVIL ENGINEERING CONTEXT

The long running dispute between the taxpayer (SSE Generation Limited) and HMRC in relation to what constitutes plant in the context of a hydroelectric power plant and civil engineering project has reached a conclusion in the Court of Appeal.

The case had previously been heard through the First […]

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

By : Julie Davies December 3, 2019 No Comments

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 […]

Capital Allowances Plant and Machinery in a Civil Engineering Context Update

By : Julie Davies February 28, 2019 Comments Off

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 […]

Capital Allowances Plant and Machinery in a Civil Engineering Context

By : Julie Davies October 3, 2018 Comments Off

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 […]