The Tribunal refused the application, concluding that while the underlying tax dispute involving £2 billion in Research and Development (R&D) allowances for Hinkley Point C is undeniably complex, the specific appeal against the information notice did not meet the necessary threshold requirements.

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.

A rates mitigation scheme for 'occupation' might be effective for non-domestic rates purposes but is unlikely to withstand scrutiny for 'use' in claims for Structures and Buildings Allowances.