EPISODE · Aug 9, 2025 · 44 MIN
S1 Ep8: Beneficial tax treatments available for expenditure on Research & Development
from Pump Court Tax Chat
Thomas Chacko and Quinlan Windle discuss the options for tax breaks in relation to spending on R&D:outline of scheme and changes made in 2024what R&D meanscan you claim when R&D is contracted outpractical points about how to deal with enquiries bearing in mind recent case law1:25 outline of the scheme pre the Finance Act 2024 - basic deduction and 2 further possible schemes (relief for small and medium enterprises + R&D credit).2:54 effect of Finance Act 20243:23 what is R&D? A common question as well as major issue in many of the cases.8:03 the effect of HMRC now taking very robust stance on R&D tax credit claims and requiring cases to pass a very high threshold. Issues with highly technical areas eg software. Tax payers must be able to explain highly technical projects to HMRC/tribunal in a way that enables them to understand why the work merits the tax credit.18:40 restrictions on qualifying expenditure in recent case law and following the Finance Act 2024.37:09 practical problems in enquiries and litigation. Also the use of ADR.CitationsLegislation and guidelinesCorporation Tax Act 2009Finance Act 2024BEIS Guidelines - latest update March 2023 (originally the DTI Guidelines)HMRC Guidance - CIRD84250HMRC CIRD161000Case lawHadee Engineering Co Ltd v Revenue & Customs [2020] UKFTT 497 (TC)BE Studios v Smith & Williamson Ltd [2005] EWHC 1506Flame Tree Publishing v HMRC [2024] UKFTT 349 (TC)Get Onbord v HMRC [2024] UKFTT 617 (TCC)Quinn (London) Ltd v HMRC [2021] UKFTT 437 (TC)Collins Construction Ltd (TC09332) - 21 October 2024Stage One Creative Services [2024] UKFTT 1059 (TC)
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S1 Ep8: Beneficial tax treatments available for expenditure on Research & Development
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