UPDATE ON LAND REMEDIATION RELIEF CASE
UPPER TIER TRIBUNAL – 21st JULY 2021
NORTHERN GAS NETWORKS LTD V THE COMMISSIONERS FOR HMRC
Following the decision reached by the First Tier Tribunal (FTT) where they agreed with HMRC’s decision to refuse a claim for land remediation relief, the case was appealed by Northern Gas Networks Limited […]
Read moreLONDON LUTON BPRA PROPERTY FUND LLP V THE COMMISSIONERS FOR HMRC
Following the decision reached by the First Tier Tribunal (FTT) that a significant amount of costs incurred by London Luton BPRA Property Fund LLP (Fund) to OVL (developer) ‘in connection with’ the conversion of a disused flight training centre into a hotel qualified for BPRA, […]
Read moreCapital Allowances denied on satellite launch costs
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 […]
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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 […]
Read moreCHESHIRE 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 […]
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 […]
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 […]
Read moreWhile 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 […]
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