Weekly case highlights ― 25 November 2024

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.

Business tax

Cobalt Data Centre v HMRC

The Tyne Riverside Enterprise Zone’s tax-favoured status came to an end nearly 20 years ago, but it is only with this Supreme Court decision that finality has been reached in respect of the tax position of a data centre building at the zone. Yet that dispute is essentially only about the meaning of a single word: ‘under’. Expenditure incurred ‘under’ a contract entered into during the life of an Enterprise Zone qualifies for relief if it is incurred within ten years of the cessation of the zone’s tax-favoured status. Here, a so-called golden contract was signed two days before the end of the tax-favoured status period. This set out a range of alternative projects

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