BAILII is celebrating 24 years of free online access to the law! Would you consider making a contribution?
No donation is too small. If every visitor before 31 December gives just £1, it will have a significant impact on BAILII's ability to continue providing free access to the law.
Thank you very much for your support!
 |
[Home] [Databases] [World Law] [Multidatabase Search] [Help] [Feedback] | |
First-tier Tribunal (Tax) |
||
|
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> GUNFLEET SANDS LIMITED GUNFLEET SANDS II LIMITED WALNEY (UK) OFFSHORE WINDFARMS LIMITE DORSTED WEST OF DUDDON SANDS (UK) LIMITED v Revenue & Customs (CORPORATION TAX - Capital allowances) [2022] UKFTT 35 (TC) (03 February 2022) URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08387.html Cite as: [2022] STI 249, [2022] UKFTT 35 (TC) |
||
[New search] [Contents list] [Printable PDF version] [Help]
| Decision Number: | TC 08387 |
| Appellant: | GUNFLEET SANDS LIMITED GUNFLEET SANDS II LIMITED WALNEY (UK) OFFSHORE WINDFARMS LIMITED ORSTED WEST OF DUDDON SANDS (UK) LIMITED |
| Respondent: | Her Majesty's Revenue & Customs |
|
Chairmen / Special Commissioners: |
|
| Date Of Decision: | 03/02/2022 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | CORPORATION TAX - Capital allowances - s11 Capital Allowances Act 2001 - expenditure incurred on studies relating to the design and construction of offshore windfarms and their component parts including wind turbines and electrical cables - are the windfarms single items of plant - yes - in the alternative the wind turbines and electrical cables are single items of plant - was the expenditure on the studies incurred on the provision of such plant - yes in some cases but no in others - to the extent that it was not so incurred, could it be treated as pre- trading revenue expenditure and deductible under section 61 Corporation Tax Act 2009 - no - in light of the wording of the closure notices and the consequential amendments to the appellants returns, did they have to prove those items of expenditure - yes - were the amounts of qualifying expenditure set out in the appellants returns "finally determined" for the purposes of paragraph 88 of Schedule 18 to the Finance Act 1998 - no - appeal allowed in part. |
