Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
In Urenco Chemplants Ltd and another v HMRC [2022] UKUT 22 (TCC) (reported in Tax Journal 11 February 2022) the Upper Tribunal (UT) ruled that the First-tier Tribunal (FTT) had made certain errors of law in reaching its decision to deny the taxpayer plant and machinery capital allowances in respect of expenditure on a nuclear tails management facility (TMF) a facility dealing with depleted uranium. Following the Court of Appeal decision in HMRC v SSE Generation Ltd [2021] EWCA Civ 105 the UT decision in Cheshire Cavity Storage 1 Ltd & another v HMRC [2021] UT 0156 and even the subsequent FTT decision in Gunfleet Sands Ltd and others v HMRC [2022] UKFTT 35 (TC)...
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Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
In Urenco Chemplants Ltd and another v HMRC [2022] UKUT 22 (TCC) (reported in Tax Journal 11 February 2022) the Upper Tribunal (UT) ruled that the First-tier Tribunal (FTT) had made certain errors of law in reaching its decision to deny the taxpayer plant and machinery capital allowances in respect of expenditure on a nuclear tails management facility (TMF) a facility dealing with depleted uranium. Following the Court of Appeal decision in HMRC v SSE Generation Ltd [2021] EWCA Civ 105 the UT decision in Cheshire Cavity Storage 1 Ltd & another v HMRC [2021] UT 0156 and even the subsequent FTT decision in Gunfleet Sands Ltd and others v HMRC [2022] UKFTT 35 (TC)...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
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