||All England Reporter
|| All ER (D) 183 (Jun)
|| EWCA Civ 545
||Court of Appeal, Civil Division
Carnwath, Hallett and Lawrence Collins LJJ
||Timothy Brennan QC (instructed by the Solicitor for Revenue and Customs) for the commissioners.
||Giles Goodfellow QC and James Rivett (instructed by Gregory Rowcliffe Milners) for the taxpayer.
||19 June 2007
Capital allowances - Industrial building or structure - Warehouse - Taxpayer using warehouse for storage of products used in the manufacture of other goods and materials - Whether taxpayer using warehouse 'for the purposes of a trade which consists in the storage of qualifying goods - , s 18(1)(f)(i), (2).
Capital allowances Industrial building or structure. Capital allowances Industrial building or structure. The expression 'a part of a trade which consists in the storage (of qualifying goods)' in s18 of the should be interpreted in accordance with its ordinary meaning. There had to be a 'sufficient distinction' between the relevant activity and other aspects of the trade to enable one to say that the activity was one part of the trade.
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