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Inmarsat Global v HMRC

In Inmarsat Global v HMRC [2019] UKFTT 558 (30 August 2019) the FTT found that the lessee of satellites could not claim capital allowances in relation to the satellites.

Inmarsat had succeeded to the activities previously carried on by the International Maritime Satellite Organisation (IMSO). Six satellites had been acquired (and paid for) by lessors and leased to IMSO which had arranged for all the satellites to be put into service by launching them and had incurred the costs of launching. The lessors of the satellites had claimed capital allowances on their capital expenditure incurred in the acquisition of the satellites (but not on the expenditure incurred by IMSO on their launch). IMSO subsequently transferred its business to Inmarsat and the lease agreements relating to the satellites were novated so that from the time of the business transfer the satellites were leased to Inmarsat which was...

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