Richard Lewis Director and David Cobb Partner in Deloitte's Research & Development Tax Services Group find some gaps in the scope of qualifying costs for R&D tax relief
In most R&D tax relief claims by far the largest part of the claim will be staffing costs. Relief is given by statute for 'the earnings [emoluments prior to 6 April 2003] paid by the company to directors or employees of the company' (FA 2000 Sch 20 para 5(1)(a)). In many cases especially where a standalone company is making the claim the wording of the legislation will not present any problem. However there will often be situations where a company's or group's employment arrangements do not fit squarely with this wording. This article looks at four situations...
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Richard Lewis Director and David Cobb Partner in Deloitte's Research & Development Tax Services Group find some gaps in the scope of qualifying costs for R&D tax relief
In most R&D tax relief claims by far the largest part of the claim will be staffing costs. Relief is given by statute for 'the earnings [emoluments prior to 6 April 2003] paid by the company to directors or employees of the company' (FA 2000 Sch 20 para 5(1)(a)). In many cases especially where a standalone company is making the claim the wording of the legislation will not present any problem. However there will often be situations where a company's or group's employment arrangements do not fit squarely with this wording. This article looks at four situations...
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