Two LLPs were not entitled to enterprise zone allowances in relation to expenditures incurred on their relevant interests in buildings. 

Summary 

Two LLPs were not entitled to enterprise zone allowances (EZAs) in relation to expenditure incurred on their relevant interests in buildings. 

Background 

On 4 April 2011, the appellant limited liability partnerships (LLPs) acquired rights under a construction contract (the ‘Golden Contract’ (GC)) between (among others) a developer and a contractor. The GC related to construction works to be undertaken at a site that was (from February 1996 to 18 February 2006) within an enterprise zone. The rights under the GC were the rights to have data centres built and fitted out (the ‘GC rights’). In April 2011, the developer made substantial advance payments to the contractor. The appellants considered that these payments