Nature of storage
M imported hardware for PVC windows and doors manufactured by its Austrian parent company. M held a large number of items in stock. The company appealed against amendments made to its corporation tax self assessment for the accounting periods ended 31 December 1999 and 2000. These amendments refused M's claim for industrial buildings allowances on a warehouse.
It was accepted that the warehouse was used for the purpose of the trade but the issue was whether it was used for the purposes of a trade or part of a trade consisting of the storage of goods. M claimed that storage of goods was a significant part of its trade because of the manufacturing processes in Austria and the delivery times required by customers. HMRC said that the taxpayer's trade was buying and selling products and that storage was inherent in wholesaling.
The Special Commissioner found...
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