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HMRC v Northumbrian Water

In HMRC v Northumbrian Water [2015] UKUT 93 (13 March 2015) the UT confirmed that a wide interpretation of ‘site’ should prevail for the purpose of the aggregate levy.

Northumbrian Water is a water and sewerage company which had engaged in construction work for the raising of the level of a reservoir. Gravel which was needed to achieve this was obtained from a nearby pit. The issue was whether the use of that gravel amounted to commercial exploitation of aggregates for the purpose of FA 2001 Part 2.

It was accepted that the gravel was aggregate. If the only exploitation resulted in the aggregate in its natural form becoming part of the land at the site from which it was extracted that exploitation did not count as commercial exploitation. The FTT had found that a purposive interpretation was required. It had considered that exploitation by way...

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