Northern Gas Network v Revenue and Customs (Corporation Tax – Land Remediation Relief): FTTTx 2 Mar 2020

CORPORATION TAX – land remediation relief – did the replacement or improvement of iron gas mains satisfy the conditions in paragraph 12 of Schedule 22 Finance Act 2001 to qualify for relief for remediation of contaminated land – no – in certain cases, the Appellant had not acquired rights in or over land in the United Kingdom whilst, in other cases, although the Appellant had acquired such rights and the land was in a contaminated state at the time of acquisition by virtue of the gas in the pipes at that time, the expenditure incurred by the Appellant was not ‘on’ or ‘in relation to’ the land and was therefore not ‘qualifying land remediation expenditure’ and, in any event, the land was in a contaminated state by virtue of something done or omitted to be done by a person with a ‘relevant connection’ to the Appellant

Citations:

[2020] UKFTT 121 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 09 November 2022; Ref: scu.649210