The tax treatment of major maritime infrastructure has now taken another turn following a decision by Upper Tribunal (Tax and Chancery Chamber) to allow an appeal by HM Revenue and Customs (HMRC) against a previous FTT ruling which accepted a claim by The Mersey Docks and Harbour Company Limited (MDHC) for £57,134,538 in plant and machinery allowances for constructing a massive Quay Wall at the Port of Liverpool.