Brought back down to Earth – Capital Allowances denied on satellite launch costs

By : Julie Davies June 3, 2021 No Comments

Overview

The First-tier Tribunal (FTT) and Upper Tribunal (UT) both found in favour of HMRC in denying Inmarsat Global Limited capital allowances on the launch costs of six leased satellites during the 1990s. Inmarsat had succeeded the trade of The International Maritime Satellite Organisation (IMSO), who had initially incurred the launch costs. Inmarsat deemed a sale […]

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 […]

Underground Gas Storage Cavities & Capital Allowances

By : Julie Davies November 20, 2019 No Comments

CHESHIRE CAVITY STORAGE 1 LIMITED and EDF ENERGY (GAS STORAGE HOLE HOUSE) LIMITED V HMRC [2019]

FIRST TIER TRIBUNAL TAX CHAMBER (FTT)

Background

Both
appellants were companies in the EDF Energy PLC Corporate Group and they
operate gas storage facilities on adjoining site is Cheshire. The Companies
used underground cavities filled with brine to store gas and incurred costs […]

Definition of what Constitutes Qualifying Expenditure for BPRA Claims

By : Julie Davies May 9, 2019 No Comments

LONDON LUTON HOTEL BPRA PROPERTY FUND LLP V THE COMMISSIONERS FOR HMRC

FIRST TIER TRIBUNAL TAX CHAMBER

This is a significant case heard by the First Tier Tribunal
(FTT) concerning a BPRA claim and the definition of qualifying expenditure ‘on
or in connection with’. HMRC have
typically considered that BPRA claims often include items of expenditure that
they deem […]

Capital Allowances: HMRC Clutching Straws on a Grain Storage Structure

By : Julie Davies February 13, 2019 Comments Off

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 […]

Employees Claiming Capital Allowances: Caravan Case Demonstrates Hurdles!

By : Julie Davies March 8, 2017 Comments Off

While the majority of Capital Allowances claims are made for businesses and trades, it is also possible for employees to claim Capital Allowances on plant and machinery. A recent UK First Tier Tribunal (FTT) case highlights the complexities of such claims and the hurdles that have to be cleared in order for claims to be […]