HMRC have become increasingly reluctant to approve research and development claims. The recent cases of Get Onbord v HMRC and Tills Plus v HMRC provide some support for taxpayers: both suggesting that HMRC’s threshold for approving research may be too high and making clear that HMRC need to explain why a project does not qualify if the taxpayer has made a serious case for why it does. Early preparation for these disputes is key. The right witnesses need to be before the tribunal in order to explain the technical difficulties clearly.
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HMRC have become increasingly reluctant to approve research and development claims. The recent cases of Get Onbord v HMRC and Tills Plus v HMRC provide some support for taxpayers: both suggesting that HMRC’s threshold for approving research may be too high and making clear that HMRC need to explain why a project does not qualify if the taxpayer has made a serious case for why it does. Early preparation for these disputes is key. The right witnesses need to be before the tribunal in order to explain the technical difficulties clearly.
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