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.
Citations:
[2022] UKFTT 35 (TC)
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 26 April 2022; Ref: scu.675639