SSE Generation: when is a tunnel a tunnel?

Will Scott

It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.

In HMRC v SSE Generation Ltd [2023] UKSC 17 (reported in Tax Journal 22 May 2023) the Supreme Court dismissed HMRC’s appeal in respect of the availability of capital allowances on expenditure incurred by SSE Generation Ltd (SSE) in connection with the construction of certain ‘conduits’ used for transporting water. The decision is the latest in a line of cases (Cheshire Cavity Storage 1 Ltd and another v HMRC [2021] UKUT 156 (TCC) Urenco Chemplants Ltd and another v HMRC [2022] UKUT 22 (TCC) and Gunfleet Sands Ltd and others v HMRC [2022] UKFTT 35 (TC)) looking at the tricky issue of the availability of capital allowances in respect of increasingly novel technologies used in the power generation industry....

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It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.