The First-tier Tribunal in Vaccine Research Limited Partnership v HMRC [2013] UKFTT 333 (TC) (TC00274) found that a partnership only qualified for research and development allowances on the part of its expenditure ultimately applied by a sub-contractor on that specific activity. In this respect the decision is a common sense one that echoes other recent decisions analysing the true purpose of a taxpayer’s expenditure. The curious part of the decision is that the tribunal saw a need to dissect the partnership’s single activity into trading and non-trading elements – thereby complicating an already difficult trading analysis.
The facts
The case concerned a Jersey limited partnership which purported to trade in the UK. Individual investors contributed £107m to the partnership capital £86m of...
