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Insights
Technical commentary on capital allowances, property and related tax matters.
Articles are provided for general information only and do not constitute advice.



Farming Partnership Loses Holiday Cottage Tax Claim
A salient reminder on the need for owners (in this case a farming partnership) to plan all stages for tax purposes

Bryan Crawford
Aug 5, 20212 min read


Expenditure in Connection With
Taxpayer succeeds on a number of points at Upper Tribunal with its hotel BPRA claim

Bryan Crawford
Aug 5, 20214 min read


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

Bryan Crawford
Aug 5, 20214 min read


Free Online Super Deductions Course
A short online course on the new capital allowances super deductions designed to inform students on how the relief operates, key timings etc

Bryan Crawford
Jun 24, 20211 min read


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

Bryan Crawford
May 5, 20213 min read


A Badly Drafted Closure Notice
This case concerns closure notices in a capital allowances claim for software licenses held in 2018.

Bryan Crawford
May 5, 20213 min read


Notable Victory for Eurocentral Investors
This was a notable victory for the taxpayer as some £13m of tax allowances depended almost entirely on the true meaning of 'temporary'.

Bryan Crawford
May 5, 20213 min read


Satellite Launch Costs
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

Bryan Crawford
Apr 7, 20214 min read


Gas Storage Caverns as Plant
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

Bryan Crawford
Apr 7, 20215 min read


Super Deductions for Landlords Update
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

Bryan Crawford
Apr 7, 20212 min read


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

Bryan Crawford
Mar 3, 20214 min read


Reduce Workload and Costs in Your Claims
How do you get the best capital allowances results for your business for the least amount of work and hassle – the answer could lie in sampling your fixed asset project additions instead of full project analysis. What is often not widely understood is that businesses can select a sample of projects (e.g., from multiple takeaway outlets) to look at in detail and extrapolate the findings to the total project population. For example, if a company reported gross capital of expend

Bryan Crawford
Feb 8, 20214 min read
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