The FTT decision in SSE Generation Ltd considered the allocation of capital allowances for expenditure on a large hydroelectric power project. The essential question concerned whether elements of the project which might appear to be excluded structures under the CAA 2001 s 22 should be treated as allowable plant or machinery. In interpreting the meaning of items in CAA 2001 ss 21–23, the FTT decided that regard had to be given to the context in which the items appeared. It also provided an important clarification to the seemingly broad exemption for expenditure in s 22(1)(b) relating to ‘any works involving the alteration of land’.
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