[2026] UKUT 00142 (TCC) CATS NORTH SEA LIMITED v HMRC
Upper Tribunal Tax and Chancery decision of Judge Raghavan and Judge Greenbank on 7 April 2026.
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CAPITAL ALLOWANCES – balancing charges – transfer of a hydrocarbon pipeline to wholly owned subsidiary - Interaction of s279 CTA 2010 (deemed separate trade for “oil-related activities”) and Part 22 CTA 2010 (intra-group transfer of trade provisions) – correct method of pooling - appeal allowed and FTT decision set aside and remade