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Gunfleet Sands Ltd and others v HMRC

In Gunfleet Sands Ltd and others v HMRC [2022] UKFTT 35 (TC) (3 February 2022) the FTT considered capital allowances claims for expenditure incurred on various studies carried out prior to the construction of windfarms.

The four appellant companies were members of the same group and each owned and operated an offshore windfarm for the generation and sale of electricity.  Each company claimed capital allowances for expenditure incurred in the construction of the windfarms. Following an enquiry HMRC disputed that allowances were available for expenditure on: environmental impact studies and assessments; metocean studies (studies on water level wave regime currents and wind conditions); geophysical and geotechnical studies; and project management design and procurement. 

The question for the FTT was whether the expenditure in dispute was ‘on the provision’ of plant. It was common ground that that expression extended beyond the price actually paid for the...

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