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 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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Capital Allowances Case Summary – Rogate Services

By : January 12, 2015 Comments Off on Capital Allowances Case Summary – Rogate Services

Capital Allowances Case Summary: Rogate Services Limited v HMRC [2014]

Release Date: 25 March 2014

Overview  

Whether expenditure on constructing a Car Valeting Bay is plant.

It was held by the First-Tier Tax Tribunal that the valeting bay was not plant. The building does not perform a function, it was a place of work which does not amount […]

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Capital Allowances Case Summary – LLPs and AIA

By : September 26, 2014 Comments Off on Capital Allowances Case Summary – LLPs and AIA

Tax Case Summary: Drilling Global Consultant LLP v HMRC [2014]

Release Date: 11 September 2014

Overview

Whether an LLP, whose members are an individual and a limited company is a qualifying person entitled to claim the annual investment allowance (AIA)  within the meaning of s38A(3)of CAA2001.

It was held by the First-Tier Tax Tribunal that a mixed LLP, […]

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