Externally Provided Workers – A Result?

Readers may recall that I wrote a Blog on 6 September calling for changes in the Externally Provided Worker (EPW) rules. In fact, I have been calling for changes in these rules for some time (see the article published in Tax Adviser). I won't rehearse the arguments in full in this post, suffice it to [...]

By |December 8th, 2011|Uncategorized|

Autumn Statement Announcements

Well, what a busy Statement and probably slightly more on the tax front than we were expecting! On the capital allowances front, the Chancellor confirmed that 100% allowances would be made available for investment in Plant & Machinery in 6 enterprise zones; the Black Country, Humber, Liverpool, North Eastern, Sheffield and Tees Valley. Unlike the EZAs [...]

By |November 29th, 2011|Uncategorized|

Another perspective on the GAAR Report

Following on from my post on 21/11/11 with my initial thoughts on Graham Aaronson’s report on a possible GAAR, I wanted to take a look the report from a slightly different perspective.  What are the ‘hidden messages’ in that report? Of course, I have to acknowledge upfront that I might have completely misread the report [...]

By |November 24th, 2011|Uncategorized|

Is a new GAAR on the way?

The Treasury published this morning a report from Graham Aaronson QC on the subject of a General Anti-Avoidance Rule.  Aaronson was asked by the Government in November 2010 to look into this. His report, which the Government took 10 days to make public, sets out the views of Aaronson and his team on this question. [...]

By |November 21st, 2011|Uncategorized|

HMRC launch R&D Advance Assurance Pilot – quietly!

At the end of last week, HMRC announced the launch of its R&D Advance Assurance Pilot (as blogged on here on 26 September). Did you spot the announcement? Unfortunately, it was rather hidden away and wasn't even referenced on its "What's New" page. The Pilot relies upon HMRC being able to get sufficient numbers of [...]

By |November 3rd, 2011|Uncategorized|

Comments on HMRC’s draft guidance on “Production”

As I Blogged on 2nd September, HMRC have been consulting on draft guidance on the meaning of "production" for R&D purposes.  This guidance, once finalised, will replace the guidance currently contained in CIRD81350.  This latest draft guidance represents quite a step from what had been a very entrenched position for HMRC; it is just a [...]

By |September 27th, 2011|Uncategorized|

R&D Claims: HMRC proposes an ‘Advance Assurance’ Pilot

HMRC is proposing to run a pilot of an Advance Assurance programme for SMEs wishing to claim R&D relief.  The idea in summary is that the smaller SMEs (no more than 50 employees) who are considering making their first R&D claim will be able to contact the relevant specialist R&D unit [contact details here] for [...]

By |September 26th, 2011|Uncategorized|

Should we move to an above the line R&D credit?

One of the options put forward in the latest (June 2011) R&D consultation document is a move to an above the line credit (ATL).  This proposal comes in response to comments made by various respondents to the earlier (November 2010) consultation exercise.  Before looking at the answer to this question, it would be sensible to [...]

By |September 22nd, 2011|Uncategorized|

Update on the R&D Consultation

The R&D Working Group, set up by HMT and HMRC, met yesterday afternoon to get feedback from sub-groups on three specific issues: An above the line credit Subcontracting Advanced assurance These issues had been delegated to sub groups to consider and feed back thoughts. HMT indicated that around 50 responses to the consultation document had [...]

By |September 21st, 2011|Uncategorized|

Response to the latest consultation on R&D

Read my response to the latest round of consultation on the R&D regimes. There are quite a few changes to the regimes being considered by HMT/HMRC and they are engaging in a useful dialogue with industry and tax advisers to ensure a good outcome.  Even though the formal consultation period is over, dialogue continues; I [...]

By |September 8th, 2011|Uncategorized|