(1) GUNFLEET SANDS LIMITED (2) GUNFLEET SANDS II LIMITED (3) WALNEY (UK) OFFSHORE WINDFARMS LIMITED (4) ORSTED WEST OF DUDDON SANDS (UK) LIMITED v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2023] UKUT 00260 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Swami Raghavan and Judge Tracey Bowler on 26 October 2023
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CORPORATION TAX 鈥� s11 Capital Allowances Act 2001 鈥� taxpayers designed and constructed offshore windfarms 鈥� FTT entitled to hold wind turbines and cables together were single item of plant 鈥� HMRC鈥檚 appeal dismissed 鈥� whether expenditure on environmental and technical studies qualified for allowance as expenditure 鈥渙n provision of plant鈥� 鈥� no 鈥� jurisdiction of the tribunal where HMRC had made the wrong amendment to a return 鈥� when an amount in a tax return is conclusively determined 鈥� Schedule 18 Finance Act 1998
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Published 27 October 2023