The Court of Appeal dismissed HMRC's appeal against the decision of the Upper Tribunal (UT) that expenditure on various structures of a hydroelectric power generation scheme was eligible for plant and machinery capital allowances, apart from the tribunal's conclusion on one particular category of expenditure. 

Summary

The Court of Appeal dismissed the appeal of HM Revenue and Customs (HMRC) against the decision of the UT that expenditure on various structures of a hydroelectric power generation scheme was eligible for plant and machinery capital allowances, apart from the tribunal's conclusion on one particular category of expenditure.

Background

The company (SSEG) claimed capital allowances on fixed asset expenditure in relation to the Glendoe Hydroelectric Power Scheme. Following enquiries by HMRC, various closure notices for the years ending 31 March 2006 to 31 March 2012