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Has the House of Lords done the Government a favour?

With all the bluster emanating from the Government benches at the moment that might seem a surprising suggestion. Cameron and Osborne are, however, showing themselves to be quite adept at setting traps for their political opponents. I can't help but feel that the defeat of the welfare reforms in the Lords was an example of [...]

By |October 27th, 2015|Government, Welfare Reform|

Whither the Patent Box? Part 2

I recently blogged on the publication of Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, the final report on Action 5 of the OECD BEPS project. In that blog I suggested that any revised Patent Box regime in the UK was likely to be so complex – in order to comply [...]

By |October 22nd, 2015|Patent Box|

Whither the Patent Box?

Earlier this month the OECD published its final report on Action 5 of its BEPS project. The report - niftily titled Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance includes a section on the Substantial activity requirement in the context of IP regimes. In other words, the requirements for the design [...]

By |October 16th, 2015|Patent Box|

Challenging HMRC’s views on reimbursed expenses in R&D claims

As anyone familiar with R&D tax relief claims will know, one of the main items of qualifying expenditure included in most claims will be the company's relevant Staff Costs. Since the relief was first introduced in FA2000 it has been accepted that reimbursed expenses form part of Staff Costs. At least, that is my experience [...]

By |September 16th, 2015|R&D|

Latest R&D Statistics

HMRC has just published the latest statistics on R&D tax relief claims for the 2013/14 year. I'm not proposing to try and analyse them in detail but there are a couple of interesting points that stand out for me. SME Claims Once again, it is SMEs that are leading the growth in the number of [...]

By |September 15th, 2015|R&D|

Taxation should be by statute, not code of practice.

On 22 July, HMRC published a consultation on Improving large business tax compliance. The scope of this consultation is defined as follows. At the 2015 Summer Budget, the Government confirmed its intention to consult on measures intended to improve large business tax compliance. These measures are designed to drive further behavioural change in the large [...]

By |July 24th, 2015|Anti Avoidance, Consultation|

Is Rob Wilson MP really that lazy?

Poor old Rob Wilson, Conservative MP for Reading East, has been getting some stick lately for claiming 9p mileage on an expense claim. The issue for me is not that he claimed the tiny sum of 9p but that he drove 0.2 miles. That's a return journey of course, so 0.1 mile there and 0.1 [...]

By |July 22nd, 2015|Uncategorized|

R&D Consultative Committee Meeting – 13 July 2015

I attended the latest meeting of HMRC's R&D Consultative Committee (RDCC) yesterday. This proved to be a very useful meeting and my notes of the meeting can be downloaded here. Note: These are my own notes from the meeting. They have not been reviewed by any of the other attendees and do not represent an [...]

By |July 14th, 2015|R&D|

The Summer Budget and Patent Box

Now that we've all had a chance to read and digest what was announced in yesterday's budget, what about what wasn't said? There was no mention of patent box. We might have expected some mention of the changes that will have to be made to the UK's patent box regime in order to make it [...]

By |July 9th, 2015|Uncategorized|

Summer Budget 2015

The Chancellor, George Osborne, delivered his first Budget of the new Parliament today. As well as being the first of this new Parliament, it was also the first Budget of a majority Conservative Government since November 1996. This is, of course, the second budget of 2015, the first having been delivered in March, before the [...]

By |July 8th, 2015|AIA, Budget, Capital Allowances, Intangible Assets, R&D|