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Overseas companies and UK R&D relief

17 February 2020 / David Ward , Peter Courtney
Issue: 4732 / Categories: Comment & Analysis
15257
Genuine proposal

Key points

  • Overseas companies can claim UK research and development tax relief but the application of the rules to a UK permanent establishment of an overseas company can be difficult.
  • Using a UK company addresses several of the pitfalls but cross-border intragroup arrangements can still raise challenges.
  • HMRC is concerned about abuse of tax relief by companies artificially set up to claim when they have little or no employment or activity in the UK.
  • It is important for genuine companies to be able to evidence the factual basis in support of their claim.
  • Structuring and documenting arrangements correctly can have a significant impact on the support available.

The UK’s research and development (R&D) tax incentive regimes are designed to promote private sector investment in innovation. Small and medium-sized enterprises...

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