Corporation tax – capital allowances – finance lease of ship by Appellant – whether ship used for a qualifying purpose within terms of section 123(1) Capital Allowances Act 2001 – UK company taking bareboat charter of ship and hiring ship on time charter terms – whether ship let on charter in course of trade including operating ships – yes – whether responsible for navigating and managing the ship and for defraying substantially all operating expenses of ship – yes – whether section 123(4) Capital Allowances Act 2001 can apply where section 110 (rather than section 109) Capital Allowances Act 2001 is in point – yes – whether on facts one of main objects of the letting of the ship on charter or of any related transaction was to obtain capital allowances: section 123(4) Capital Allowances Act 2001 – no – appeal allowed
Citations:
[2012] UKFTT 47 (TC), [2012] SFTD 572, [2012] STI 1203
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 23 June 2022; Ref: scu.450811
