Weekly case highlights ― 8 February 2021

Produced by Tolley
Weekly case highlights ― 8 February 2021

The following Owner-Managed Businesses guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Weekly case highlights ― 8 February 2021
  • Business tax
  • HMRC v SSE Generation Ltd
  • Income tax
  • Sharon Clipperton and another v HMRC
  • VAT
  • St George’s University Ltd v HMRC
  • SDLT
  • Edward and another v HMRC
  • Tax administration
  • More...

These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.

Business tax

HMRC v SSE Generation Ltd

Have you ever had cause to wonder what is meant by the word ‘tunnel’? You or I may not have, but the judges of the Court of Appeal had to consider the question in the context of this case, which is concerned with how much of the construction costs of a hydro-electric power scheme qualified for capital allowances. As the judges noted, it is ironic that the whole project was completed within three years whereas it has already taken over 10 years to resolve the tax position.

The court held that most, though not all, of the disputed expenditure did qualify for capital allowances. Few readers will have clients who are developing power stations, but there is much of interest in this decision for all concerned with capital allowances, particularly when dealing with the boundaries between what is plant and what is a building. The rules here are extraordinarily complex, with

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