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SSE Generation v HMRC

Capital allowances applied to a hydroelectric scheme

In SSE Generation v HMRC [2018] UKFTT 416 (31 July 2018) the FTT allowed the appeal in part finding that most of the relevant items qualified for capital allowances under the Capital Allowances Act (CAA) 2001.

SSE was involved in the generation transmission distribution and supply of electricity and the production storage distribution and supply of gas and various associated energy services. It had constructed the first large-scale hydroelectric scheme with a conventional hydraulic head feed built in the UK in the last 50 years. This appeal was concerned with expenditure incurred in both the original construction of the scheme and the subsequent remedial works.

The issue was the availability of capital allowances on each of the items comprised in the scheme; the question was whether they fell within CAA 2001 s 21 List A or...

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