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In Cheshire Cavity Storage 1 Limited -and- EDF Energy (Gas Storage Hole House) Limited v HMRC [2019] TC07301 the FTT dismissed claims to capital allowances on underground gas storage cavities; they were not plant and machinery.

A person who is engaged in Qualifying activities can claim capital allowances on qualifying expenditure on plant and machinery:

Both appellants were companies in the EDF Energy PLC corporate group. The two companies operate gas storage facilities on adjoining sites in Cheshire.

The FTT dismissed the appeal finding that:

Links to our guides:

Plant & machinery (companies): allowances

What expenditure qualifies for plant and machinery allowances 

External link:

Cheshire Cavity Storage 1 Limited -and- EDF Energy (Gas Storage Hole House) Limited v HMRC [2019] TC07301