Insights

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

Compiling a claim to withstand HMRC scrutiny takes planning and care but the rewards can be significant - don't lose out!

Article exploring the most common areas of opportunity in balance sheet and construction project tax analysis

Taxpayer succeeds on a number of points at Upper Tribunal with its hotel BPRA claim

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

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

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

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

On 5th February the government passed the legislation announced in Budget 2020 to extend and tighten the availability of 100% First Year Allowances for low emission cars. The measure is designed to incentivise the uptake of zero CO2 emission vehicles by businesses and support the Government’s announcement of its desire to phase out the sale of new petrol, diesel and hybrid cars from 2030. This is also intended to support its wider policy on climate change to reduce all greenh

The case of Revenue and Customs Commissioners v SSE Generation Ltd [2021] will be of interest to anyone involved in capital allowances because it discusses in some detail the application and principles behind the statutory ‘structure’ exclusions contained in the Capital Allowances Act (‘CAA’) 2001 s22 and its potential exemptions in CAA 2001 s23 – List C. More specifically, how narrowly some of the terms in s22 need to be construed and applied as well as what needs to be cons

The UK Government open up a bidding process in England to establish at least seven new Freeports.

When it comes to determining repairs for tax purposes, words matter but substance and context matter more

Here we set out some of the key issues we expect to be examined for property additions to meet Covid-19.

LRR remains the only real tax incentive for businesses who clean up contaminated or long-term derelict land and buildings.

Budget 2020 – Capital Allowances Summary

HM Revenue & Customs (“HMRC”) have updated their manuals on long life assets (LLAs) to remind affected taxpayers that the concept of ‘entity’ or ‘entirety’ for the purposes of applying the LLA rules is a question of tax law and not accounting opinion. For example, a capital allowance claim for an underground cable system (including television, telecommunications, or electricity supply systems) will often include the costs of excavating the land and providing ducting that hous

The Office of Tax Simplification has published a document setting out the scope of a new review into simplifying claims and elections.