Does anyone have some insight into how Generation Tariff is being taxed in practice? BIM40510 suggests that, where the supply by an individual is not made in a business capacity, there would be no charge under the miscellaneous income provisions "where an individual generates electricity mainly for use in their own home".
A key question: is 'mainly' being interpreted as 'more than 50%' (in line with the 'wholly or mainly' interpretation used in various places through the UK tax legislation), or as 'the amount produced should not exceed domestic needs by more than 20%' (in line with the income tax exemption for Export Tariff production that does not 'significantly exceed' domestic use - s 782A ITTOIA)?
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Feed in Tariff Legislation
I believe that the feed in tariff legislation states that the income from the FIT is not taxable in the hands of a the home owner, and that this overrides the taxation legislation. The selling points for the feed in tariffs are tha tthey are guaranteed for 25 years, index linked and tax free. I would suggest reviewing the FIT legislation.