Wellstead v Revenue and Customs (INCOME TAX/CORPORATION TAX : Capital allowances) [2016] UKFTT 492 (TC)

FTT-Tax
Wellstead v Revenue and Customs (INCOME TAX/CORPORATION TAX : Capital allowances)
[2016] UKFTT 492 (TC) · 2016-02-08
[33]The Court of Appeal considered what policy reason there might be for denying relief to a charity where it purchased jointly with a non-charity. The court found that there was no policy reason to deny relief. It then referred to a number of authorities defining the boundaries between the role of a court in construing legislation and the power of Parliament to legislate. In particular in Inco Europe Ltd v First Choice Distribution [2000] 1 WLR 586 at 592 where Lord Nicholls said:
“ It has long been established that the role of the courts in construing legislation is not confined to resolving ambiguities in statutory language. The court must be able to correct obvious drafting errors. In suitable cases, in discharging its interpretative function the court will add words, or omit words or substitute words … This power is confined to plain cases of drafting mistakes. The courts are ever mindful that their constitutional role in this field is interpretative. They must abstain from any course which might have the appearance of judicial legislation. A statute is expressed in language approved and enacted by the legislature. So the courts exercise considerable caution before adding or omitting or substituting words. Before interpreting a statute in this way the court must be abundantly sure of three matters: (1) the intended purpose of the statute or provision in question; (2) that by inadvertence the draftsman and Parliament failed to give effect to that purpose in the provision in question; and (3) the substance of the provision Parliament would have made, although not necessarily the precise words Parliament would have used, had the error in the Bill been noticed. The third of these conditions is of crucial importance. Otherwise any attempt to determine the meaning of the enactment would cross the boundary between construction and legislation. ” 34. The court in Pollen Estate also referred to the words of Lord Reid in Luke v IRC [1963] AC 557 at 577: “ To apply the words literally is to defeat the obvious intention of the legislation and to produce a wholly unreasonable result. To achieve the obvious intention and produce a reasonable result we must do some violence to the words. This is not a new problem, though our standard of drafting is such that it rarely emerges. The general principle is well settled. It is only where the words are absolutely incapable of a construction which will accord with the apparent intention of the provision and will avoid a wholly unreasonable result, that the words of the enactment must prevail. ” 35. The court then went on to construe paragraph 1(1) adding the highlighted words as follows: “A land transaction is exempt from the charge to the extent that the purchaser is a charity and the following conditions are met …”
. The court considered that “ … there is sufficient ‘policy imperative’ to justify the reading… Not to afford a charity relief in such circumstances would, in my judgment, be capricious ”. 36. In the present case Mr Mullan effectively submitted that the ambiguity in the statutory provisions could be resolved without the need to add, omit or substitute any words. He did not rely on any obvious drafting error nor did he accept that is was necessary to do any violence to the words used in CAA 2001. The underlying policy of IBAs could be respected and what would otherwise be an unreasonable result could be avoided with a purposive construction of the words used. To that extent therefore he did not suggest that we were in the realms of Inco Europe or Luke v IRC. 37. At first sight the interest of HCL when it built Unit 2 was the Lease. It was not the same interest that was transferred by HCL to Mr Wellstead, namely the Underlease. The issue before us is really whether a purposive construction of the provisions, in particular section 286, gives a different result. 38. Mr Mullan submitted that the legislation for IBAs was designed amongst other things to encourage expenditure in enterprise zones. In the context of that overriding purpose there was no policy reason or rationale for a distinction between the Lease and the Underlease on the present facts. The term “interest in the building” in section 286 should not be construed in a narrow technical sense. Regard should be had to the nature of the rights enjoyed by the person incurring the expenditure. In the case of HCL it had a right to use and occupy the building for a period of 125 years from 24 August 2001. The intention of the parties had been to put Mr Wellstead in the same position. Because of conveyancing technicalities the Lease could not simply be assigned, because it was a lease of both Unit 1 and Unit 2, and Unit 1 had not yet been sold. The reality however was that in a practical sense all HCL’s right and interest in Unit 2 was sold to Mr Wellstead by way of the Underlease. All that HCL retained was the right to use and occupy the premises for 5 days at the end of the 125 year period. There was therefore a sale of the relevant interest by HCL to Mr Wellstead. 39. That result was consistent, said Mr Mullan, with a realistic and purposive construction of the provisions. Any other result would be inconsistent with the purpose of the legislation which was to grant IBAs to those incurring expenditure on buildings in enterprise zones. Mr Wellstead had incurred such expenditure. 40. If that was the extent of Mr Mullan’s submissions we think he would have been in some difficulty persuading us that the provisions could be given such a purposive construction. Importantly however Mr Mullan relied on the terms of section 288(1) set out above. For the sake of convenience we repeat them here:
“ 288(1) An interest does not cease to be the relevant interest merely because of the creation of a lease or other interest to which that interest is subject. (2) This is subject to any election under section 290. ” 41. Mr Mullan emphasised use of the word “merely” in that sub-section. Section 288(1) refers to the position where a lease or other subordinate interest is created, to which the relevant interest is subject. He submitted that the effect of section 288(1) was that the grant of a subordinate interest will not “ on its own ” cause an interest to cease to be a relevant interest. The implication was that depending on the circumstances the grant of a subordinate interest could cause an interest to cease to be a relevant interest. 42. Mr Mullan submitted that the question whether the grant of a sub-lease causes a lease to cease to be a relevant interest would involve consideration of the terms of the sub-lease. In particular the grant of a sub-lease where the lessor did not retain any valuable interest in a building might cause a lease to cease to be a relevant interest. It was implicit in Mr Mullan’s submissions that if in those circumstances the lease ceased to be a relevant interest, the purposive construction of section 286 meant that the granting of a sub-lease would be treated as the sale of a relevant interest. If the grant of a sub-lease could never amount to the sale of a relevant interest then section 288(1) would be unnecessary. On that basis Mr Mullan submitted that it was not necessary to omit, add or substitute any words in the legislation to arrive at a result consistent with the policy intention of Parliament. Nor was it necessary to do violence to the words of the statute. 43. We were also referred to the decision of Megarry J in Sargaison v Roberts [1969] 1 WLR 951 as support for the proposition that niceties of English land law should not affect the availability of capital allowances. In that case the taxpayer was a farmer who acquired freehold property in 1957 and incurred considerable capital expenditure that qualified for allowances. In 1964 he settled the freehold on trust for the benefit of his family, and the trustees immediately granted a 40 year lease to the taxpayer so that he could continue farming. The Inland Revenue refused a capital allowances claim in 1965-66 on the basis that the taxpayer had transferred the whole of his interest in the land to some other person, namely the trustees within section 314(4) Income Tax Act 1952. 44. The general commissioners allowed the taxpayer’s appeal and Megarry J dismissed an appeal by the inspector of taxes. He held that whilst there was a notional instant during which the taxpayer had no interest in the land, the reality was that his interest had been reduced from freehold ownership to a long lease and he had not transferred the whole of his interest in the land. He was supported in that conclusion by his view that the Act was not drafted in terms of English property law but in broader and less technical language. He concluded that the statutory provision was intended to operate broadly, without fine technical distinctions. 45. We do not consider that Sargaison v Roberts provides much if any real support for Mr Mullan’s arguments in the context of the provisions we are asked to construe. More important are the words used by Parliament in the statute, together with the broad context and policy which underpin IBAs. 46. Mr Bracegirdle submitted that the legislation made specific provision for circumstances where there was more than one interest in a building. On the facts of the present case there were three interests in Unit 2 – the freehold, the Lease and the Underlease. The possibility of more than one interest in a building made it important to define precisely the interest which was relevant for IBA purposes. He relied on the express wording of section 286(3) which makes provision for more than one interest in a building. Where one of the interests is reversionary on the other it is the reversionary interest which is the relevant interest. 47. Mr Bracegirdle also relied on section 359(5). Section 286(1) which sets out the general rule as to what is the relevant interest, is expressly subject to section 359. Section 359 makes provision for new leases arising on the termination of a lease to be treated as a continuation of the original lease. Section 359(5) provides as follows: “ 359(5) If on the termination [of a lease] – (a) another lease is granted to a different lessee, and (b) in connection with the transaction that lessee pays a sum to the person who was the lessee under the first lease, the two leases are to be treated as if they were the same lease which had been assigned by the lessee under the first lease to the lessee under the second lease in consideration of the payment. ” 48. Section 359(5) could apply in the circumstances of the present appeal if there had been a surrender of the Lease together with a re-grant of a lease by the freeholder to Mr Wellstead. Obviously that would require a willingness on the part of the freeholder to grant a new lease directly to Mr Wellstead, which it may or may not have been willing to do. It might also apply to some form of partition of the Lease. 49. Mr Mullan accepted that in theory it might have been possible for there to have been some form of partition of the lease and an assignment of that part relating to Unit 2. We do not know whether HMRC would have maintained an argument that a partitioned lease of Unit 2 would not be the same interest as the relevant interest which was a lease of both units. 50. Mr Bracegirdle submitted that if Parliament had intended to treat the grant of a long lease as a sale of the relevant interest then it could easily have done so. However it restricted relief in such circumstances to sub-leases exceeding 50 years between non-connected persons and where an election was made. It did not intend IBAs to be available generally in the case of sub-leases outside sections 290 and 291. He submitted that was the only qualification to the general rule in section 288(1) that an interest does not cease to be a relevant interest because of the creation of a subordinate interest. 51. The difficulty with Mr Bracegirdle’s construction of section 288 is that the word “merely” in section 288(1) is rendered unnecessary. It is not necessary to include that word simply, as Mr Bracegirdle suggested, to lead the reader to sub-section (2). Sub-section (2) naturally follows from and qualifies sub-section (1) without any need for the word “merely”
. Mr Bracegirdle did acknowledge that on his construction if the word was not simply introducing the qualification in sub-section (2) then it served no useful purpose. 52. Mr Bracegirdle maintained that the legislation was highly prescriptive about the meaning of relevant interest, in particular the circumstances where the grant of a lease exceeding 50 years could be treated as a sale of the relevant interest. It was therefore hard to see why the statute would not have set out more detail as to the circumstances in which the grant of a lease generally might be treated as the sale of the relevant interest. 53. We agree with Mr Mullan’s submissions in relation to section 288. As a matter of law the grant of a lease or a sub-lease does not affect the nature of the interest out of which it is granted, whether it is a freehold or a leasehold interest. The leaseholder owns the same interest in the property before and after the grant of a sub-lease. However these provisions introduce the concept of a relevant interest, which governs entitlement to IBAs. It seems to us that Parliament, in enacting section 288(1), anticipated that there may be circumstances where the grant of a lease might cause a relevant interest to cease to exist for the purposes of the scheme of the legislation. However the grant of a sub-lease would not, on its own, cause a headlease to cease to be a relevant interest. Adopting that construction the legislation begs the following questions: (1) In what circumstances might the grant of a sub-lease mean that the lease will cease to be a relevant interest, and (2) What is the effect of a lease ceasing to be a relevant interest as the result of the grant of a sub-lease. In particular, does the granting of the sub-lease amount to a sale of the relevant interest. 54. As to the first question we agree with Mr Mullan that the legislation does not specify in what circumstances the granting of a sub-lease might cause the relevant interest to cease to exist because it is inevitably a matter of degree. As Mr Mullan said, a sub-lease could come in all shapes and sizes. It would be difficult for Parliament to prescribe all the circumstances in which the grant of a sub-lease might amount to the transfer of a relevant interest and therefore the matter is left for interpretation on the particular facts of the case. To that extent we do not consider that the legislation is highly prescriptive. What is prescriptive is the circumstances in which the grant of any lease of more than 50 years will amount to a sale of the relevant interest. 55. It is certainly the case from the scheme of the legislation that there can only be one relevant interest. The granting of a sub-lease does not automatically cause the headlease to cease to be the relevant interest. One specific situation in which the grant of a sub-lease will cause a headlease to cease to be the relevant interest is in section 290. That is where the sub-lease is for more than 50 years, it is granted to a non-connected person and the appropriate election is made. However the legislation does not say that that is the only circumstance in which the grant of a sub-lease will amount to a sale of the relevant interest. 56. Section 290(2) expressly provides that IBAs will be available for cases falling within section 290(1) “as if” the grant of the sub-lease were a sale of the relevant interest. It seems to us that the provisions of section 290 provide an opportunity for certainty in the case of a sub-lease of more than 50 years, regardless of the length of the reversionary interest. It is not however inconsistent with making IBAs available to the purchaser of a sub-lease generally where the question of whether there has been a sale of the relevant interest will be a matter of degree. 57. Section 290(2) implicitly provides the answer to the second question as to the effect of an interest ceasing to be a relevant interest following the grant of a sub-lease. The provisions are to apply as if the grant of the sub-lease were a sale of the relevant interest. Mr Bracegirdle did not suggest that the effect of a relevant interest ceasing to be a relevant interest by virtue of section 288(1) would be anything other than a sale of the relevant interest. 58. Mr Bracegirdle pointed to the strict qualifying conditions for IBAs including qualifying expenditure on a qualifying building. The construction contended for by the Respondents produced what he described as an entirely reasonable result. It was entirely reasonable to treat separate interests in a different way. However he could not identify any policy reason why IBA’s should be available to a purchaser by way of assignment of a headlease but not available to a purchaser of a sub-lease for the whole term of the headlease, save a few days. In particular if the economic effect of a sub-lease is the same as an assignment then there is no policy reason why IBAs should not be available. It was not suggested that there was any policy connected with tax avoidance or abuse of the provisions which should distinguish those situations. Certainly there is no suggestion that the transactions between HCL and Mr Wellstead were in any way connected with tax avoidance. 59. It is notable in this context that the Sale Agreement anticipated two methods of completion. Either the grant of a sub-lease of Unit 2 or, if Unit 1 had previously been sold by way of sub-lease, an assignment of the Lease. Whatever method of completion was adopted the consideration payable by Mr Wellstead was £1m. That serves to highlight the fact that there was no commercial difference between the Lease in so far as it affected Unit 2 and the Underlease. Mr Bracegirdle had submitted that on the facts of the present case the Lease continued to have value in relation to Unit 1 which was not affected by the Underlease of Unit 2. However the provisions for IBAs are concerned with the relevant interest in the building. Plainly if Mr Wellstead had taken an assignment of the Lease before Unit 1 had been sold it would have cost him considerably more than the £1m he paid. There is no policy reason why he should not be entitled to IBAs on a purchase of only Unit 2. 60. Mr Mullan’s overarching submission was that the grant of the Underlease answered the statutory description of a sale of the relevant interest with the result that the purchase price paid by Mr Wellstead qualified for IBAs. For the reasons given above we accept that submission. Conclusion 61. In all the circumstances we allow the appeal. 62. This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice. JONATHAN CANNAN TRIBUNAL JUDGE RELEASE DATE: 13 JULY 2016