½Û×ÓÊÓƵ

Collins Construction Ltd v HMRC

This is an important R&D case about the rules which prevent a company obtaining relief where the expenditure on which relief is claim is subsidised. How broadly should that term be interpreted?

The company here was a building company which carried out construction contracts for large companies. As part of delivering a project it might need to carry out research and development work ― for example, in one building it had to create a solution to deal with reverberation. It was accepted that this work was R&D The question was whether the fact that the costs of this work were incorporated into the overall charge to the customer meant that the customer was subsidising