Matthew Hodkin and David Schultz (Norton Rose Fulbright) consider the broader implications of an FTT decision on capital allowances for expenditure on a hydroelectric power project.
In SSE Generation v HMRC [2018] UKFTT 416 (31 July 2018) the First-tier Tribunal (FTT) considered capital allowance claims made by SSE Generation Ltd (SSE) an energy company in respect of its newly constructed hydroelectric power generation scheme at Glendoe in Scotland (‘the project’). The total cost of the project was approximately £300m of which SSE claimed capital allowances under CAA 2001 for plant and machinery totalling £227m. HMRC allowed £34m of this claim and disputed the remainder on the basis that it was excluded by either CAA 1990 ss 21 or 22 and was not saved by s 23.
In a brief recap of the legislation:
s 21 contains a list of assets (list A) that...
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Matthew Hodkin and David Schultz (Norton Rose Fulbright) consider the broader implications of an FTT decision on capital allowances for expenditure on a hydroelectric power project.
In SSE Generation v HMRC [2018] UKFTT 416 (31 July 2018) the First-tier Tribunal (FTT) considered capital allowance claims made by SSE Generation Ltd (SSE) an energy company in respect of its newly constructed hydroelectric power generation scheme at Glendoe in Scotland (‘the project’). The total cost of the project was approximately £300m of which SSE claimed capital allowances under CAA 2001 for plant and machinery totalling £227m. HMRC allowed £34m of this claim and disputed the remainder on the basis that it was excluded by either CAA 1990 ss 21 or 22 and was not saved by s 23.
In a brief recap of the legislation:
s 21 contains a list of assets (list A) that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
