(Sub)contracted R&D: Is HMRC getting it right?

Subcontracted research and development (R&D) has been a rather turbulent topic in the R&D tax relief world for years. It’s important to get it right: as we know the scheme aims to generate value by incentivising uncertain projects that otherwise may not be taken on stimulating economic activity and increasing the knowledge and skill base here in the UK.

Where this activity requires multiple parties the question of which party (or in some cases parties) is the eligible claimant becomes crucial – for the scheme to return maximum value it should incentivise the right people. Furthermore if left unchecked multiple claimants for the same project would be inevitable and could become rife leading to HMRC investing several tax benefits for the same activity even further undermining its return on investment.

Being able to identify the ownership of the...