Tribunal decision in R&D case

The FTT has allowed the appeal of Collins Construction Ltd and its claim for R&D tax relief. The decision concerns the issues of whether expenditure is ‘subsidised’ or activities are ‘subcontracted’ for the purposes of CTA 2009 Part 13. This marks an important decision on the principles of a relief that has been the subject of a great deal of scrutiny in recent years.

Edward Hellier appeared for Collins Construction Ltd, Francis Fitzpatrick KC and Sarah Black appeared for HMRC. A copy of the decision can be found here.