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Case Law – Mersey Docks & Harbour Company v HMRC

HMRC continue to raise enquiries and to disallow items of plant that could be used for a claimant’s trade. This case relates to the quay wall at the Port of Liverpool

14 Jan 2025

Written by: Clive Curd

Case Law – Changi Airport Loses $273m Tax Break

Changi Airport Group (CAG) made Capital Allowances claims over three years totalling $272,575,162 on assets including the runways and taxiways but lost with the Court of Appeal determining that the assets were structures and not tools of trade.

20 Dec 2024

Written by: Tom Lo

Furnished Holiday Lets – HMRC Clarify Legislation

The window to claim Capital Allowances tax relief on furnished holiday lettings (FHLs) is fast decreasing before repeal of the legislation in April 2025 and HMRC have now clarified the transitional rules about who can or can't claim.

07 Nov 2024

Written by: David Gibson

Archive

 

Latest News

Case Law – Mersey Docks & Harbour Company v HMRC

14 Jan 2025

HMRC continue to raise enquiries and to disallow items of plant that could be used for a claimant’s trade. This case relates to the quay wall at the Port of Liverpool

Case Law – Changi Airport Loses $273m Tax Break

20 Dec 2024

Changi Airport Group (CAG) made Capital Allowances claims over three years totalling $272,575,162 on assets including the runways and taxiways but lost with the Court of Appeal determining that the assets were structures and not tools of trade.

Furnished Holiday Lets – HMRC Clarify Legislation

07 Nov 2024

The window to claim Capital Allowances tax relief on furnished holiday lettings (FHLs) is fast decreasing before repeal of the legislation in April 2025 and HMRC have now clarified the transitional rules about who can or can't claim.

New Case Law – Capital v Revenue

04 Oct 2024

A recent important Supreme Court decision in Centrica Overseas Holdings Limited v HMRC addresses the deductibility of expenses incurred by a company. The bar to deduct costs has been raised considerably

HMRC To Increase Scrutiny on Capital Allowances Claims

04 Oct 2024

Not only are Allowances more advantageous than ever before, but HMRC are strategically targeting tax leakage – including through Capital Allowances. Getting the correct advice is essential

100% Full Expensing – What is it and why it’s important

09 Sep 2024

Hailed as the “Greatest Tax Break in History” when it was introduced in 2021, the 130% Super Deduction aimed to take some of the sting away from the hike in Corporation Tax rate that was announced in the same speech. Its replacement, Full Expensing (FE), took over in April 2023 as a slightly less headline-grabby 100% First Year Allowance. But what is it?

Some Good News for Furnished Holiday Let Owners

05 Aug 2024

Positive transitional rules have now been published allowing Furnished Holiday Let owners the ability to use Capital Allowances beyond April 2025

Case Ruling – HMRC v Altrad Services Limited

10 Jul 2024

The decision by the Court of Appeal will have far reaching implications in that it clearly resets the boundaries of what is a capital allowances avoidance scheme designed to increase the quantum of capital allowances claimed

Spring Budget Update

06 Mar 2024

Chancellor Jeremey Hunt announces changes to the capital allowances legislation affecting furnished holiday let owners

The accelerated 130% super deduction and new 100% full expensing capital allowances are set to drive an increase in HMRC enquiries into Capital Allowances claims, increasing the importance of preparing fully substantiated claims, supported by case law and legislation.

In March this year HMRC started to issue ‘nudge letters’ to companies who have claimed the 130% super deduction and 50% special rate allowance prompting companies to check their basis of claim for these first year allowances with an initial focus on leasing restrictions and companies with an accounting period straddling 1 April 2021.

Nudge Letters – What are they?

It is a cost effective form of communication by HMRC sent to taxpayers who HMRC believe have a tax issue to disclose. HMRC have recently targeted Research and Development Claims which offer significant accelerated tax reliefs, and it is expected there will be a similar push for Capital Allowances claimants who have and will benefit from the new 100% full expensing allowances, in addition to the super deduction claims.

It is also expected that HMRC will open enquiries into those that do not respond or make a full disclosure.

HMRC are requesting companies to provide evidence of the asset purchase contract, when the asset was brought into use, correspondence or the date when the supplier was first approached, delivery dates, copies of invoices etc.

This emphasises the importance of a robust claim report and the need to disclose this within the relevant tax return; a blanket claim approach will not be adequate.

Veritas Advisory recommend using an experienced specialist capital allowances advisor as this avoids any pitfalls in claiming the first year allowances, ensures the tax savings are maximised, and ultimately is able to withstand an HMRC enquiry being raised into your tax return.