United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> HM Revenue & Customs v Lloyds TSB Equipment Leasing (No.1) Ltd [2013] UKUT 368 (TCC) (14 August 2013)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2013/368.html
Cite as: [2013] UKUT 368 (TCC), [2014] STC 191, [2013] BTC 2016, [2013] STI 2985

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HM Revenue & Customs v Lloyds TSB Equipment Leasing (No.1) Ltd [2013] UKUT 368 (TCC) (14 August 2013)

"CORPORATION TAX - Claim for capital allowances in respect of ships where the end sub-lease was to a non-UK resident user - Time charter to that end user granted by a UK resident company that claimed that its role (as the disponent owner under the time charter) satisfied the terms of section 123 Capital Allowances Act 2001, and therefore constituted a "qualifying user" so preserving the Respondent finance leasing company’s entitlement to 25% writing-down allowances - Three issues the subject of the appeal by HMRC, and one the subject of a cross-appeal by the Respondent"

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