Market leading insight for tax experts
View online issue

HMRC v Lloyds TSB Equipment Leasing

In HMRC v Lloyds TSB Equipment Leasing (No. 1) Ltd (Upper Tribunal – 15 August) a UK company (L) which carried on a trade of finance leasing claimed capital allowances on expenditure on two ships which were designed and built to ship liquefied natural gas from Norway to Spain and the USA. HMRC issued an amendment rejecting the claim considering that the effect of CAA 2001 s 123(4) was that L was not entitled to the allowances it had claimed. The First-tier Tribunal (FTT) allowed L’s appeal holding that the ships were used for a ‘qualifying purpose’ within CAA 2001 s 123(1) and that the restriction imposed by s 123(4) did not apply so that L was entitled to allowances. The Upper Tribunal upheld this decision (by the casting vote of Newey J with Judge Nowlan dissenting).

Read the...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.