James Dudbridge (ForrestBrown) discusses HMRC's revised guidance that concedes their previous position on contracted-out R&D and subsidised expenditure.
HMRC’s new guidance on subsidised expenditure and contracted-out R&D had been anticipated for several months. Its seeds however were sown years ago.
In 2019 a curious R&D case found its way to the courts. Hadee Engineering Co Ltd v HMRC [2020] UKFTT 497 (TC) is a case with limited significance today but it was arguably the starting gun for a major dispute between taxpayers (and their advisers) and HMRC over two restrictions to SME R&D tax relief: activities which are contracted-out and expenditure which is subsidised.
The journey since has been long and frequently frustrating but the recent publication of HMRC’s revised guidance on these two restrictions represents the landing ground of that journey. The hope was a new world of certainty and clarity. While these aspirations haven’t...
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James Dudbridge (ForrestBrown) discusses HMRC's revised guidance that concedes their previous position on contracted-out R&D and subsidised expenditure.
HMRC’s new guidance on subsidised expenditure and contracted-out R&D had been anticipated for several months. Its seeds however were sown years ago.
In 2019 a curious R&D case found its way to the courts. Hadee Engineering Co Ltd v HMRC [2020] UKFTT 497 (TC) is a case with limited significance today but it was arguably the starting gun for a major dispute between taxpayers (and their advisers) and HMRC over two restrictions to SME R&D tax relief: activities which are contracted-out and expenditure which is subsidised.
The journey since has been long and frequently frustrating but the recent publication of HMRC’s revised guidance on these two restrictions represents the landing ground of that journey. The hope was a new world of certainty and clarity. While these aspirations haven’t...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
