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Capital allowances for structures, assets and works

Steven Bone (Gateley Capitus) examines a recent Upper Tribunal decision about capital allowances for structures and land alterations in the context of a hydroelectric power civil engineering scheme.

In the recent decision of HMRC v SSE Generation Ltd [2019] UKUT 332 (TCC) the Upper Tribunal (UT) ruled on the capital allowances treatment of a major hydroelectric power scheme in Scotland.

Whilst few tax advisers are likely to become involved in works of this nature and scale the decision covers various issues relevant to civil engineering projects and capital allowances claims more generally.

Summary of the works

Water is collected from two high ground catchment areas. It is fed from streams via water intakes into a network of conduits. The conduits channel the water into a main reservoir behind a dam at the head of a river...

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