First-tier Tribunal (Tax)

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URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08387.html
Cite as: [2022] STI 249, [2022] UKFTT 35 (TC)

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Decision Number:	TC 08387
Appellant:	GUNFLEET SANDS LIMITED GUNFLEET SANDS II LIMITED WALNEY (UK) OFFSHORE WINDFARMS LIMITED ORSTED WEST OF DUDDON SANDS (UK) LIMITED
Respondent:	Her Majesty's Revenue & Customs
Chairmen / Special Commissioners:
Date Of Decision:	03/02/2022
Main Category:	PROCEDURE
Main Subcategory:	Other
Notes:	CORPORATION TAX - Capital allowances - s11 Capital Allowances Act 2001 - expenditure incurred on studies relating to the design and construction of offshore windfarms and their component parts including wind turbines and electrical cables - are the windfarms single items of plant - yes - in the alternative the wind turbines and electrical cables are single items of plant - was the expenditure on the studies incurred on the provision of such plant - yes in some cases but no in others - to the extent that it was not so incurred, could it be treated as pre- trading revenue expenditure and deductible under section 61 Corporation Tax Act 2009 - no - in light of the wording of the closure notices and the consequential amendments to the appellants returns, did they have to prove those items of expenditure - yes - were the amounts of qualifying expenditure set out in the appellants returns "finally determined" for the purposes of paragraph 88 of Schedule 18 to the Finance Act 1998 - no - appeal allowed in part.

PDF Copy: [2022] UKFTT 35 (TC)

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