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I’ve been reading with interest HMRC’s new guidance on research and development (R&D) (tinyurl.com/hmrcranddguidoct23) – oddly headed up ‘promotional material’. This is an area of great interest to me but, although I have in the past advised clients on R&D, I don’t have any recent experience so it is not appropriate for me to comment in detail in this note. We have commissioned an article on this new guidance from a leading adviser in this area which will be published shortly.
But I do want to make some general observations. First of all, it is right that HMRC has published this new guidance. We all know of the problems that have plagued the R&D reliefs market in the last few years and, at the very least, it is useful for HMRC to have put a marker down in the ground about where the boundaries lie. I am sure that there will be some debates about whether it has been put in the right place, but I can live with that.
Second, I do think that this guidance is well written and clear. I know from my own experience that writing good quality guidance is a difficult task and it is too easy either to waffle on without saying anything or be so obscure that you can’t understand what is being said. The authors have taken real care to set this out well with good examples. In other areas HMRC’s examples have often been only at the extreme ends of the spectrum, where there is generally little dispute. Here it seems to me that the examples are more mainstream and thus likely to be of real value to practitioners and taxpayers alike.
More of the same please.
If you do one thing...
If you deal with partnerships, note that the relevant sections of the Enquiry Manual have been completely rewritten. See tinyurl.com/hmrcem7000.
