RESEARCH-AND-DEVELOPMENT

R&D claim succeeds before FTT.

FTT rejects HMRC’s interpretation of contracted out expenditure in R&D rules.

SDLT MDR claim denied: Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT,...

Thomas Chacko

In two recent cases, the tribunal approached the question of what was qualifying research in a way that supports taxpayers’ claims, if the right evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).

Carried interest base cost shift: In N Millican v HMRC [2024] UKFTT 618 (TC) (5 July), the FTT upheld the taxpayer’s appeal that his disposal of an interest in a company did not fall within the special regime in the TCGA 1992 which applies...

Carrie Rutland

James Rolfe

Carrie Rutland and James Rolfe (BDO) highlight practical issues concerning the introduction of the new scheme which takes effect from April.

Gerald Montagu

It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).

Justine Dignam

The latest R&D reforms were said to simplify the tax regime and encourage business investment. The reality though is more complexity, writes Justine Dignam (Markel Tax).

James Shorland

James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.

Ian Rowland Kenneth Nugent Lindsey Copland

HMRC is consulting on a single scheme for R&D tax relief to replace the existing SME and RDEC schemes. The timetable is an ambitious one and much needs to be considered, write Lindsey Copland, Ian Rowland and Kenneth Nugent (Grant Thornton).

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