The First Tier Tribunal (FTT) ruled that studies and project management costs relating to the building of offshore wind farms partly qualified for capital allowances and that HMRC needs to amend the closure notices given to the companies.

Four companies, who were members of the same group, each owned and operated an offshore wind farm for the generation and sale of electricity.

Gunfleet Sands, Gunfleet Sands II, Walney (UK) Offshore Windfarms, and Orsted West of Duddon Sands (WODS) incurred expenditure of approximately £48m in relation to the construction of offshore wind farms and the studies that supported the creation.

The studies included environmental impact studies and assessments, ocean studies, including studies on water level, wave regime, currents and wind conditions, and geophysical and geotechnical studies.