Alun Oliver
Capital allowances narrowed: UKSC sides with HMRC on pre-development costs
Managing Director·E3 Consulting·Capital allowances; property tax; infrastructure
Profile
Oliver founded E3 Consulting and built it into one of the UK's specialist capital allowances practices. A Fellow of the Royal Institution of Chartered Surveyors, he contributes to Tax Journal. In his 13 February 2026 Tax Journal piece, he previewed the Supreme Court hearing in Orsted Sands, setting out the Crown's narrower reading of section 11(4) against Jones KC's argument rooted in the legislation. Judgment was handed down on 15 April ([2026] UKSC 12): the Supreme Court unanimously allowed HMRC's appeal and overturned the Court of Appeal, imposing a narrower reading of section 11(4) Capital Allowances Act 2001.