The Supreme Court ruled that SSE Generation was entitled to deduct £200m in capital allowances spent building underground channels for a hydroelectric power station at Glendoe in Scotland.

HMRC disputed certain allowances claimed by SSE for the tax years 31 March 2006 to 31 March 2012 on the basis that in their view certain relevant assets did not give rise to allowable expenditure under the Capital Allowances Act 2001 (CAA 2001).