Capital Allowances: Transactions and Planning 2021/22
Authors: Martin Wilson MA and Steven Bone
Capital Allowances: Transactions and Planning 2021/22
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 takes into account the following developments:
- Freeports: Enhanced structures and buildings allowances (SBAs) and capital allowances for plant and machinery at new English freeports, subject to qualifying conditions (9.13 onwards)
- Summary of amended first-year allowances for plant (14.15), including the new 130% super-deduction allowance (14.17A) and the 50% SR allowance (14.17B)
- Changes to the SME payable R&D tax credit that a loss-making company can receive (19.45)
- A summary of Payne and Anors v HMRC Commrs [2020] EWCA Civ 889 (17.3)
In addition the Case Summaries Appendix has been updated in line with a number of important cases
- Inmarsat Global Ltd V HMRC [2021] UKUT 59 (TCC) (Appendix 4)
- Cheshire Cavity Storage 1 Ltd and Anor v HMRC [2021] UKUT 50 (TCC) (15.41 and Appendix 4)
- Court of Appeal findings in SSE Generation Ltd v Commissioners for HM Revenue and Customs [2021] EWCA Civ 105 (Appendix 4)
- Upper Tribunal findings in Daarasp LLP and Betex LLP v Commissioners for HM Revenue and Customs [2021] UKUT 87 (TCC) (Appendix 4)
- Steadfast Manufacturing and Storage Ltd v Commissioners for HM Revenue and Customs [2020] UK FTT 286 (TC) (Appendix 4)
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.