Inmarsat Global Ltd v Revenue and Customs Comrs

Subject Matter

REVENUE — Corporation tax — Capital allowances — Expenditure on provision of machinery or plant — Satellite organisation commissioning construction and launch of satellites — Satellites being acquired by third party lessors and leased to satellite organisation — Satellite organisation transferring business to taxpayer — Taxpayer claiming entitlement to writing-down allowances on market value of satellites at time of transfer — Whether taxpayer entitled to writing-down allowances — Capital Allowances Act 1990, ss 61(4), 78(1)

[2021] UKUT 59 (TCC); [2021] STC 713, UT (TCC)

REVENUE — Corporation tax — Capital allowances — Expenditure on provision of machinery or plant — Satellite organisation commissioning construction and launch of satellites — Satellites being acquired by third party lessors and leased to satellite organisation — Satellite organisation transferring business to taxpayer — Taxpayer claiming entitlement to writing-down allowances on market value of satellites at time of transfer — Whether taxpayer entitled to writing-down allowances — Capital Allowances Act 1990 (c 1), ss 61(4), 78(1)

[2022] EWCA Civ 1076; [2022] STC 1426; [2022] WLR(D) 337, CA

Appellate History

Commentary

RPC Perspectives
Inmarsat Global – Upper Tribunal confirms successor company not entitled to capital allowances incurred by its predecessor on satellite launch costs Case comment