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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.



Pre Construction Costs Tax Treatment Post Orsted
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.

Bryan Crawford
Jul 156 min read


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

Bryan Crawford
Mar 18, 20255 min read


Mersey Docks wins plant and machinery status for 'Quay Wall' in Tax Tribunal
Tax Tribunal determines that expenditure on a new quay wall qualifies for plant and machinery allowances

Bryan Crawford
Jan 9, 20253 min read


Camping Pods: How their Use, Form, and Specification Affect Tax Treatment
This recent tax case concerns the capital allowances treatment of 26 timber log camping pods at an outdoor activity centre in Wales.

Bryan Crawford
Jan 19, 20244 min read


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

Bryan Crawford
Nov 22, 20235 min read


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

Bryan Crawford
Apr 11, 202211 min read


A test of the function test in a highly regulated and sophisticated asset
An article on the tax treatment of costs for specialist building parts in uranium treatment facility

Bryan Crawford
Mar 2, 20222 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


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


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


Defending Structure Claims as Plant
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

Bryan Crawford
Feb 3, 20216 min read


Short Life Asset Tax Benefits
If you spend money on plant or machinery (including certain fixtures) for use in your business and regularly dispose or scrap them..

Bryan Crawford
Oct 29, 20203 min read
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