Capital Allowances: Transactions and Planning 2022/23

Capital Allowances: Transactions and Planning 2022/23

Adopting a practical approach, and with a unique transaction-based structure and special features such as pro forma elections and checklists, this content guides you through the practical realities of a claim, rather than just presenting the bare facts of statute and case law. Legislation is comprehensively covered, but with the emphasis on interpretation and explanation, rather than mere repetition of the wording of statute.

The most recent update includes the following developments:

• Commentary on claiming R&D relief updated to reflect Megablue Technologies Ltd (in Liquidation) v HMRC[2022] UKFTT 24 (TC) (19.50)
• Qualifying expenditure - commentary updated to reflect expenditure on data and cloud computing being eligible for R&D tax relief (19.52)
• Vehicle fleet – content updated in line with the updated official vehicle approval documentation recognised for determining the level of a vehicle’s CO2 emissions for capital allowances purposes (17.3)
• Specialised structures treated as plant – commentary updated in line with InJRO Griffiths Ltd v Commissioners for HM Revenue and Customs[2021] UKFTT 257 (TC) (16.72)
• Commentary updated in line with Gunfleet Sands Ltd and Anors v HMRC Commrs[2022] UKFTT 00035 (TC) (15.11) and (14.110B); and Urenco Chemplants Ltd and Anor v HMRC Commrs [2022] UKUT 00022 (TCC) (15.20A) and (14.110A)
• Commentary on the eligibility of expenditure incurred for the super-deduction is added (14.18)
• Commentary on enhanced allowances for plant and machinery in Freeports updated (9.14)

This is essential reading for anyone incurring capital expenditure on property and looking to maximise capital allowances and related tax-related reliefs on a wide range of commercial transactions. This content has been updated by Steven Bone from Gateley Capitus (Steven.Bone@gateleycapitus.com), and Martin Wilson.

Author

Steven Bone FRICS ATT (Fellow) is a director at Gateley Capitus specialising in tax incentives for real estate investment and innovation, including capital allowances, land remediation relief and research and development relief. He is a tax-qualified chartered surveyor who has specialised in tax incentives for over 25 years in ‘Big Four’ consulting, specialist boutique and national mid-tier accountancy firms before joining the Gateley legal and professional services group. Steven is the author of several titles on tax incentives including RICS's guidance note on capital allowances and land remediation relief and ICAEW Tax Faculty updates.