Stage One Creative Services Ltd v HMRC

In Stage One Creative Services Ltd v HMRC [2024] UKFTT 1059 (TC) (25 November) the First-tier Tribunal (FTT) allowed the company’s appeal holding that it was entitled to research and development (R&D) relief under the pre-2024 regime for SMEs.

The company’s business was the provision of engineering construction and automation solutions for live events and installations. An example project involved designing building and installing a complex scenic design for a theatre show comprising an automated pearl which was flown through the theatre before opening to reveal a performer inside it. The company claimed R&D relief for expenditure incurred under various contracts. The claims were supported by detailed R&D reports. Broadly clients would approach it with a concept and would be more concerned with a particular result and not with how it was achieved. The contracts did not mention R&D and...