Insights

Capital investments, and particularly more complex investments, with greater upfront risk are likely to be most affected by the Orsted ruling with reduced qualifying costs for tax purposes. In this article we explore the tax implications of the ruling in detail.

Today's capital allowances Budget changes might sound like a giveaway with a new 40% First-Year Allowances (FYA) for all businesses (with extensions for leasing) but that 18% to 14% Writing Down Allowance (WDA) reduction for existing 'main rate' plant or machinery (P&M) means that overall HM Treasury is hoping to raise an extra £1bn to £1.5bn annually from 2026/27.

Court of Appeal decision summary on the pre-construction (operational studies) costs for a major offshore windfarm.

Tax Tribunal determines that expenditure on a new quay wall qualifies for plant and machinery allowances

In 2024, HM Revenue & Customs (HMRC) has been sharpening its focus on compliance checks for commercial real estate and infrastructure deals

An invalid s198 election is a potential win-win for HMRC an easy target - don't lose out - find out all you need to know in this article.

An article covering some of the most common tax pitfalls and opportunities on works to an existing building with tips and links.

This recent tax case concerns the capital allowances treatment of 26 timber log camping pods at an outdoor activity centre in Wales.

The Upper Tribunal (UT) has now considered last year's First-tier tax (FTT) tribunal decision on the capital allowances treatment of certain costs associated with offshore windfarms and whilst it agreed with FTT on a number of issues it took a different view on the eligibility of preliminary studies and surveys, narrowing the scope for this claim and potential claims for similar expenditure on other projects. Windfarm The UT decision concerned the following issues: - Whether

An overview of the latest developments in 'Full Expensing' following the UK Chancellor's Autumn Statement 2023

A round-up of our most popular and topical articles covering capital allowances case law, legislation changes, news and related announcement

An article examining capital allowances in commercial real estate transactions (including furnished holiday lettings)

An article on the tax treatment of costs for specialist building parts in uranium treatment facility

An article on a tax case that deals with capital allowances on the windfarm costs at Gunfleet Sands

Warehouse treated as a 'cold store' and 'silo for temporary storage' enabling capital allowances win at Tribunal.

HM Revenue & Customs (HMRC) have confirmed that they will accept the decision in the First-teir Tribunal (FTT) case of DAARASP LLP and BETEX

The recent case of Inmarsat Global Limited v The Commissioners for Her Majesty’s Revenue & Customs [2021] UKUT0059(TCC) is an appeal against a decision of the First-tier tribunal (FTT) that expenditure on the cost of launching six satellites between 1990 and 1996 was not eligible for capital allowances. It was not disputed that had the company constructed and operated the satellites the associated launch costs would qualify for plant and machinery allowances under the ‘provis

Can a hole in the ground be an item of plant or machinery? The hole here was in fact a sophisticated underground cavern which had been artificially created by dissolving rock salt and then forcing the water out to be replaced by gas, which was held for storage. The capital allowances rules for ‘plant and machinery’ generally distinguish between items which are used in a trade (qualifying) and the setting in which the trade is carried out (non-qualifying). But the distinction

Following last month’s budget announcement on the Capital Allowances Super Deduction, we have received a response from the Capital Allowances Technical team at HM Revenue & Customs (“HMRC”) confirming that claims for certain landlord areas within commercial properties should be eligible for the accelerated First Year Allowances (FYAs). Common Areas and Management Suites Although HMRC has committed to publishing full technical guidance following its initial factsheet it is not

Today’s budget announced a temporary increase in tax relief for companies who invest in certain types of new plant and machinery