In Lloyds TSB Equipment Leasing (No 1) Ltd v HMRC (TC01745 – 24 January) a UK company (L) which carried on a trade of finance leasing claimed capital allowances on expenditure on two ships which were designed and built to ship liquefied natural gas from Norway to Spain and the USA. HMRC issued an amendment rejecting the claim considering that the effect of CAA 2001 s 123(4) was that L was not entitled to the allowances it had claimed. The First-tier Tribunal allowed L’s appeal holding that the ships were used for a ‘qualifying purpose’ within CAA 2001 s 123(1). With regard to s 123(4) the Tribunal held that ‘the question which has to be answered is whether a main object of the relevant transactions was the obtaining of those allowances and this envisages that there may be a...
