INDEPENDENT CAPITAL ALLOWANCES SPECIALISTS

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Super Capital Allowances Changes Budget 2021

The Chancellor, Rishi Sunak’s budget announcement should help turbo-charge capital investments in the UK with new super capital allowances costed at £29bn over the next 4 years. The extension of loss relief carry-back to 3 years is also positive and makes claiming capital allowances a potent tool in reducing corporation tax and triggering repayments of […]

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

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 […]

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Freeports & Capital Allowances – Boosting the Economy Through Investment

As part of an ongoing consultation process, HMRC is considering the creation of Freeports across the UK.  These Freeports will be located around air, sea and rail ports and will be governed by different customs and tariff status.   Local authorities, operators of ports, airports and rail, and businesses will bid to create a designated Freeport, […]

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Capital Allowances Article: Revenue or Capital – A Concrete Decision

Steadfast Manufacturing and Storage Limited (SM&S) successfully appealed against HMRC for a revenue amendment of £13,428.20 for the accounting period ending 31 October 2015. The appellants also appealed a consequential amendment of £1,489.80 for the accounting period ended 31 October 2014. The amount initially disputed by HMRC related to expenditure incurred on a yard used […]

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Unlocking Cash – How to Maximise Through Capital Allowances

When businesses suffer catastrophic blows to their cashflow, as many are
experiencing now, it is important to explore every opportunity there is to
raise cash.

Claiming capital allowances provides such an opportunity.

Amending Tax Returns to Claim
Historic Expenditure and Reduce Tax Payable Now

Reducing tax bills is an easy way to retain cash and it is vitally
important now to maximise […]

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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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Underground Gas Storage Cavities & Capital Allowances

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 […]

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Groundhog Day – HMRC Loses Appeal To Upper Tax Tribunal: Late Capital Allowances Claim

Further to our article titled ‘The Lazarus Impact – Making very Late Capital Allowances Claims’ where the First Tier Tax Tribunal allowed a pub company (the taxpayer) to file a very late capital allowances claim. HMRC appealed the First Tier Tax Tribunal’s decision at the Upper Tax Tribunal.

The taxpayer won again and HMRC
lost the […]

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Definition of what Constitutes Qualifying Expenditure for BPRA Claims

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 […]

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