Weekly case highlights ― 4 November 2024

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.

Business tax

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

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