- Cited — London Luton Hotel BPRA Property Fund LLP v The Commissioners for HMRC 2023-04-04
“…Although it is not a case on the meaning of “in connection with”, some further assistance can be derived from Ben-Odeco Ltd v Powlson (Inspector of Taxes) [1978] 1 WLR 1093,[1978] STC 460. That case concerned the availability of capital allowances under section 41(1) of the Finance Act 1971, which contained the words “expenditure …”
- Cited — Urenco Chemplants Limited & Anor v The Commissioners for His Majesty's Revenue and Customs 2022-12-01
“… makes clear, the leading authorities on this question are two decisions of the House of Lords, Barclay, Curle and Ben-Odeco Ltd v Powlson (Inspector of Taxes) [1978] 1 WLR 1093 (“Ben-Odeco”).…”
- Cited — Inmarsat Global Limited v The Commissioners for HMRC 2022-07-28
“…ion. That involves a focus on IMSO rather than on the nature of the expenditure, contrary to Lord Wilberforce’s approach as set out in Ben-Odeco [Ltd v Powlson [1978] 1 WLR 1093].”…”
- Cited — Inmarsat Global Limited v The Commissioners for HMRC 2022-07-28
“… 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 construction of a dry dock and excavation to accommodate it. The House o…”