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Drilling Global Consultant v HMRC

In Drilling Global Consultant v HMRC [2014] UKFTT 888 (11 September 2014) the FTT held that an LLP made up of an individual and a company was not a ‘qualifying person’ for the purpose of the 100% annual investment allowance (AIA).

The appellant was an LLP whose partners were Dr Thorogood a professional drilling engineer and Thorogood Consultants a company of which Mr Thorogood and his wife were directors.

The LLP wished to claim the AIA on the upgrade of a plane used by Mr Thorogood. The question was whether the LLP was a ‘qualifying person’ under CAA 2001 s 38A and thus entitled to AIA. S 38A provides that a ‘qualifying person’ is: an individual; a partnership of which all the members are individuals; or a company.

Drilling Global contended that it was a company for these purposes as a result of CTA 2009 s...

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