References: [2013] UKUT 368 (TCC)
Links: Bailii
UTTC CORPORATION TAX – Claim for capital allowances in respect of ships where the end sub-lease was to a non-UK resident user – Time charter to that end user granted by a UK resident company that claimed that its role (as the disponent owner under the time charter) satisfied the terms of section 123 Capital Allowances Act 2001, and therefore constituted a ‘qualifying user’ so preserving the Respondent finance leasing company’s entitlement to 25% writing-down allowances – Three issues the subject of the appeal by HMRC, and one the subject of a cross-appeal by the Respondent