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 […]
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Recent Research and Development (R&D) Tax Case Implications for Capital Allowances Claims
Appeal Number: TC/2019/06690
Grazer Learning Limited appealed against HMRC for a tax credit enquiry amounting to £26,050 regarding expenditure incurred on R&D for the accounting period ending 31 October 2017. The £26,050 was initially accepted and paid to the Appellant on 6 June […]
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LONDON 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, […]
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Cheshire Cavity Storage 1 Limited & EDF Energy (Gas Storage Hole House) Limited v The Commissioners for HMRC
A recent case heard by the Upper Tier Tribunal (UTT) follows a trend of capital allowances claims being taken to Court where the disagreement between taxpayers and HMRC revolves around what is deemed to be plant (and so qualifies […]
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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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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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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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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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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 […]
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 […]
