- Cited — Urenco Chemplants Limited & Anor v The Commissioners for His Majesty's Revenue and Customs 2022-12-01
“…r fixture on the one hand or a building or structure on the other. This was the view of the minority in the House of Lords in IRC v Barclay, Curle & Co Limited [1969] 1 WLR 675, 45 TC 221. But the majority held that even a building or a structure (in that case a dry dock) could be plant if it was more appropriate to describe it as app…”
- Cited — Urenco Chemplants Limited & Anor v The Commissioners for His Majesty's Revenue and Customs 2022-12-01
“…ayer’s business, and thus to pass the premises test. The classic example of this in the English authorities is the dry dock case, IRC v Barclay, Curle & Co Ltd [1969] 1 WLR 675 (HL), where the House of Lords decided by a bare majority (Lords Hodson and Upjohn dissenting) that the cost of excavating and constructing a dry dock with dir…”
- Cited — Inmarsat Global Limited v The Commissioners for HMRC 2022-07-28
“…We were taken in this context to two decisions of the House of Lords: Inland Revenue Commissioners v Barclay, Curle & Co Ltd [1969] 1 WLR 675 (“Barclay, Curle”) and Ben-Odeco Ltd v Powlson [1978] 1 WLR 1093 (“Ben-Odeco”). In Barclay, Curle, the taxpayer had incurred capital expenditure on the constru…”
- Cited — HMRC v SSE Generation Ltd 2021-02-01
“…Section 22(2) reflects the decision of the House of Lords in Inland Revenue Commissioners v Barclay, Curle & Co Ltd [1969] 1 WLR 675. In that case it was held that the cost of excavating a new basin to create a dry dock for use in the taxpayer’s shipbuilding trade was expenditure on the prov…”