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 […]

Unlocking Cash – How to Maximise Through Capital Allowances

By : Julie Davies March 25, 2020 No Comments

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 […]

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

By : Julie Davies December 3, 2019 No Comments

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 […]

Capital Allowances Plant and Machinery in a Civil Engineering Context Update

By : Julie Davies February 28, 2019 Comments Off

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 […]

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 […]

Capital Allowances Plant and Machinery in a Civil Engineering Context

By : Julie Davies October 3, 2018 Comments Off

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 […]

OTS – Report on Proposed Capital Allowances Simplification

By : Julie Davies June 22, 2018 Comments Off

The long awaited report by the Office of Tax Simplification (OTS) into the proposed simplification of capital allowances was published on the 15th June 2018. It extends to 88 pages but concludes that whilst an accounts based depreciation system would be attractive, the benefits gained would be completely outweighed by the disruption suffered by businesses […]

Capital Allowances within Offices

By : Julie Davies September 14, 2016 Comments Off

Both owners and occupiers of office buildings can claim substantial capital allowances but this opportunity is often missed. This can be due to confusion over the recent April 2014 capital allowances rules changes or because non-specialist solicitors, accountants and tax advisors do not recognise the full potential of available allowances. Frequently, construction cost information can […]

Capital Allowances & Landlord Contributions to Tenant Fitting Out Works

By : Julie Davies December 2, 2015 Comments Off

It is sometimes essential to offer incentives to attract tenants to take space in a vacant property. Typically these will be in the form of a general cash payment, contribution to tenant fit out or a rent-free period.

Of these the contribution route can be the most tax efficient for the landlord as there is a […]

Capital Allowances within Private Member Clubs

By : Julie Davies November 11, 2015 Comments Off

There is substantial worth of tax allowances within private member clubs. Significant savings can be achieved by considering capital allowances at an early stage. In-house accountants and tax advisors will be able to identify the apparent qualifying items of plant and machinery (P&M), such as furniture, kitchen equipment etc. When fitting out or refurbishing a […]