INDEPENDENT CAPITAL ALLOWANCES SPECIALISTS

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Capital Allowances Case: SSE Generation Limited v The Commissioners for HMRC

UPPER TIER TRIBUNAL TAX CHAMBER

There have been a run of cases heard before the courts
relating to civil and structural works, with debate about what constitutes a
structure as opposed to plant. 

In August 2019, the FTT heard The Cheshire Cavity Storage 1
Limited v Anor case.  This concerned a
taxpayer who operates gas storage facilities and created […]

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Underground Gas Storage Cavities & Capital Allowances

CHESHIRE CAVITY STORAGE 1 LIMITED and EDF ENERGY (GAS STORAGE HOLE HOUSE) LIMITED V HMRC [2019]

FIRST TIER TRIBUNAL TAX CHAMBER (FTT)

Background

Both
appellants were companies in the EDF Energy PLC Corporate Group and they
operate gas storage facilities on adjoining site is Cheshire. The Companies
used underground cavities filled with brine to store gas and incurred costs […]

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Capital Allowances – Furniture, Fixtures and Equipment Expenditure

Capital Allowances – Keeping track of accounts coded Furniture, Fixtures and Equipment expenditure – Be careful!

Typically, Accountants recognise the potential to claim
allowances on accounts coded Furniture, Fixtures and Equipment (FF&E). This
is normally for directly paid invoices for equipment where the invoice
descriptions are clear and unambiguous. These are normally identified in the
commercial accounts and coded […]

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Groundhog Day – HMRC Loses Appeal To Upper Tax Tribunal: Late Capital Allowances Claim

Further to our article titled ‘The Lazarus Impact – Making very Late Capital Allowances Claims’ where the First Tier Tax Tribunal allowed a pub company (the taxpayer) to file a very late capital allowances claim. HMRC appealed the First Tier Tax Tribunal’s decision at the Upper Tax Tribunal.

The taxpayer won again and HMRC
lost the […]

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Definition of what Constitutes Qualifying Expenditure for BPRA Claims

LONDON LUTON HOTEL BPRA PROPERTY FUND LLP V THE COMMISSIONERS FOR HMRC

FIRST TIER TRIBUNAL TAX CHAMBER

This is a significant case heard by the First Tier Tribunal
(FTT) concerning a BPRA claim and the definition of qualifying expenditure ‘on
or in connection with’.  HMRC have
typically considered that BPRA claims often include items of expenditure that
they deem […]

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