The Mersey Docks and Harbour Company Ltd v HMRC

In The Mersey Docks and Harbour Company Ltd v HMRC [2024] UKFTT 1163 (TC) (23 December 2024) the the First-tier Tribunal (FTT) allowed the company’s claim for plant and machinery allowances for expenditure on constructing a quay wall as part of the development of a new port terminal in Liverpool.

The taxpayer was the operator of the Port of Liverpool. Between 2013 and 2017 it developed ‘Liverpool2’ a new deep-water container terminal at the port. The development involved the dredging of an area of the Mersey riverbed and the construction of a quay wall abutting the river and of a ‘container transition area’ (CTA) of reclaimed land behind the wall used for the storage and handling of shipping containers. Ship-to-shore (STS) cranes for loading and unloading containers from ships were installed to run on rails founded on the quay wall. ...