A limited liability partnership whose members were an individual and a company was not a ‘qualifying person’ for annual investment allowance purposes, and was therefore not entitled to claim the allowance.
The appellant, a limited liability partnership (LLP), provided consultancy services to the oil industry. The LLP members were an individual (T) and a company (TCL), the directors of which were T and his wife. TCL did not trade as such, and had no customers.
T owned an aircraft, which was used partly for the purposes of the business. The LLP paid for the aircraft’s navigation system to be upgraded during the year ended 5 April 2011. HM Revenue & Customs (HMRC) opened an enquiry into the appellant’s partnership tax return for that tax year. HMRC subsequently amended the tax return by removing the appellant's capital allowances claim for 100% annual investment allowance (AIA) in respect of the
