³ÉÈËÓ°Òô

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