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DAVID O'KEEFFE and DAVID BYWATER consider a number of practical issues impacting on the availability of research and development tax relief.
DAVID O'KEEFFE and DAVID BYWATER consider a number of practical issues impacting on the availability of research and development tax relief.
THE RESEARCH AND development (R&D) tax relief regimes for small and medium sized companies (SMEs) and large companies have been in place for just over four and two years respectively. Over that time a number of issues have come to the fore which may arise when preparing claims and also when agreeing claims with the Inland Revenue. This article looks at four such issues and considers the relevant legislation and non-statutory guidance.
Sub-contracting of research and development
The fundamental difference between the regime for SMEs and that for large companies is highlighted by the treatment of sub-contracted R&D expenditure. As a rule of thumb the SME regime provides an incentive to the company which bears the financial cost of the R&D project whereas the large...
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