The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
In R (oao Cobalt Data Centre 2 LLP and another) v HMRC [2024] UKSC 40 the Supreme Court confirmed that investors behind the construction of two data centres could not claim Enterprise Zone allowances (EZAs) on the expenditure they incurred because the developer’s rights under the contract did not extend to the fundamental changes to the construction works actually undertaken.
EZAs were valuable tax deductions for expenditure incurred in specified zones intended to encourage development and regeneration. The intention was for the regeneration to happen quickly hence the allowances were time limited.
The case concerned the construction of data centres in the Tyne Riverside enterprise zone. EZAs were only available under CAA...
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The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
In R (oao Cobalt Data Centre 2 LLP and another) v HMRC [2024] UKSC 40 the Supreme Court confirmed that investors behind the construction of two data centres could not claim Enterprise Zone allowances (EZAs) on the expenditure they incurred because the developer’s rights under the contract did not extend to the fundamental changes to the construction works actually undertaken.
EZAs were valuable tax deductions for expenditure incurred in specified zones intended to encourage development and regeneration. The intention was for the regeneration to happen quickly hence the allowances were time limited.
The case concerned the construction of data centres in the Tyne Riverside enterprise zone. EZAs were only available under CAA...
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:
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