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.

Read the full decision in The Commissioners for HM Revenue and Customs v Lloyds TSB Equipment Leasing (NO 1) Ltd: [2013] UKUT 0368 (TCC).

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.

Help us improve GOV.UK

Don’t include personal or financial information like your National Insurance number or credit card details.