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Tax tip: Research and development – subsidised and contracted out claims

20 January 2025
Issue: 4969 / Categories: Forum & Feedback
Research and development – subsidised and contracted out claims

Research and development – subsidised and contracted out claims.

HMRC has confirmed that it will not appeal its recent losses at the First-tier Tribunal relating to research and development (R&D) tax relief claims in Collins Construction Ltd (TC9358) and Stage One Creative Services Ltd (TC9332). The tribunal focused on HMRC’s position that either the R&D had been subsidised or contracted out by the customer but found in favour of the company in both cases.

HMRC is contacting taxpayers with existing enquiries this month to update them about next steps and will issue further guidance in February 2025.

Our advice follows:

  • If clients have an open enquiry and have not sought specialist advice we would strongly recommend it.
  • If clients have an open enquiry where contracted out and/or subsidised activities are the point of contention request an extension in the response time to allow for the new...

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