UPDATE ON LAND REMEDIATION RELIEF CASE
UPPER TIER TRIBUNAL – 21st JULY 2021
NORTHERN GAS NETWORKS LTD V THE COMMISSIONERS FOR HMRC
Following the decision reached by the First Tier Tribunal (FTT) where they agreed with HMRC’s decision to refuse a claim for land remediation relief, the case was appealed by Northern Gas Networks Limited […]
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Rishi Sunak has announced a welcome extension of the Annual Investment Allowance (AIA). The Annual Investment Allowance was due to reduce from £1m to £200k from 1 January 2022. However, the £1m amount has now been extended until 31 March 2023.
In addition, the Freeport sites Humber, Teeside and Thames Freeport will be designed tax sites […]
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Recent Research and Development (R&D) Tax Case Implications for Capital Allowances Claims
Appeal Number: TC/2019/06690
Grazer Learning Limited appealed against HMRC for a tax credit enquiry amounting to £26,050 regarding expenditure incurred on R&D for the accounting period ending 31 October 2017. The £26,050 was initially accepted and paid to the Appellant on 6 June […]
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LONDON LUTON BPRA PROPERTY FUND LLP V THE COMMISSIONERS FOR HMRC
Following the decision reached by the First Tier Tribunal (FTT) that a significant amount of costs incurred by London Luton BPRA Property Fund LLP (Fund) to OVL (developer) ‘in connection with’ the conversion of a disused flight training centre into a hotel qualified for BPRA, […]
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In this webinar, specialist speakers John Lovell and Kirsty Palacci will provide a masterclass in capital allowances.
The Webinar will cover:
Capital allowances in contextChanges in the 2021 BudgetSuper capital allowancesConstruction/Expenditure ClaimsPurchased Properties ClaimsFreeportsCommon misconceptionsStructures and Buildings Allowance
To view the preview video and subscribe to Lexis Nexis Webinars please click here
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Capital Allowances denied on satellite launch costs
Overview
The First-tier Tribunal (FTT) and Upper Tribunal (UT) both found in favour of HMRC in denying Inmarsat Global Limited capital allowances on the launch costs of six leased satellites during the 1990s. Inmarsat had succeeded the trade of The International Maritime Satellite Organisation (IMSO), who had initially incurred the […]
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Great news for Property companies.
Super capital allowances have been extended to Property companies. A late amendment was issued to Finance Bill 2021 as link below. This is positive as they were previously going to be denied allowances apart from to shared communal areas. It arises from an amendment to Finance Bill 2021. It removes the […]
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Cheshire Cavity Storage 1 Limited & EDF Energy (Gas Storage Hole House) Limited v The Commissioners for HMRC
A recent case heard by the Upper Tier Tribunal (UTT) follows a trend of capital allowances claims being taken to Court where the disagreement between taxpayers and HMRC revolves around what is deemed to be plant (and so qualifies […]
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The Chancellor, Rishi Sunak’s budget announcement should help turbo-charge capital investments in the UK with new super capital allowances costed at £29bn over the next 4 years. The extension of loss relief carry-back to 3 years is also positive and makes claiming capital allowances a potent tool in reducing corporation tax and triggering repayments of […]
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PLANT AND MACHINERY IN A CIVIL ENGINEERING CONTEXT
The long running dispute between the taxpayer (SSE Generation Limited) and HMRC in relation to what constitutes plant in the context of a hydroelectric power plant and civil engineering project has reached a conclusion in the Court of Appeal.
The case had previously been heard through the First […]
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