I have argued for some time that the Externally Provided Worker (EPW) rules in the R&D legislation are flawed.  They result in many genuine EPW arrangements being excluded from R&D claims and are failing to achieve their stated objectives.

In a recent article, published in Tax Adviser in July 2011, I explained how the rules were failing to achieve the policy objectives and suggested some ways of remedying the situation. I have made these same points in response to the recent R&D consultation and direct to HMRC in the R&D Working Group meetings.  I just hope that someone is listening.