The Commissioners for HM Revenue and Customs v Lloyds TSB Equipment Leasing (NO 1) Ltd: [2013] UKUT 0368 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Newey and Judge Nowlan on 14 August 2013.
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CORPORATION TAX - Claim for capital allowances in respect of ships where the end sub-lease was to a non-UK resident user - Time charter to that end user granted by a UK resident company that claimed that its role (as the disponent owner under the time charter) satisfied the terms of section 123 Capital Allowances Act 2001, and therefore constituted a “qualifying user” so preserving the Respondent finance leasing company’s entitlement to 25% writing-down allowances - Three issues the subject of the appeal by HMRC, and one the subject of a cross-appeal by the Respondent.
Published 1 December 2016