Was the obtaining of capital allowances one of the main purposes?
Our pick of this week's cases
InLloyds Bank Leasing (No. 1) v HMRC[2015] UKFTT 401 (14 August 2015) the FTT found that the obtaining of capital allowances had been one of the main objects of a transaction so that tax relief was not available.
Lloyds Bank Leasing (LBL) a finance leasing company had incurred nearly £200m in expenditure on the purchase of two ships. The issue was whether the main object or one of the main objects of the relevant transaction – which had included the letting of the ships – had been to obtain writing-down allowances. If this was the case capital allowances should be denied under CAA 2001 s 123(4).
The FTT noted that the draftsman had not intended to confine the application of s 123(4) to those...
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Was the obtaining of capital allowances one of the main purposes?
Our pick of this week's cases
InLloyds Bank Leasing (No. 1) v HMRC[2015] UKFTT 401 (14 August 2015) the FTT found that the obtaining of capital allowances had been one of the main objects of a transaction so that tax relief was not available.
Lloyds Bank Leasing (LBL) a finance leasing company had incurred nearly £200m in expenditure on the purchase of two ships. The issue was whether the main object or one of the main objects of the relevant transaction – which had included the letting of the ships – had been to obtain writing-down allowances. If this was the case capital allowances should be denied under CAA 2001 s 123(4).
The FTT noted that the draftsman had not intended to confine the application of s 123(4) to those...
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:
