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Genuine proposal
Key points
- Overseas companies can claim UK research and development tax relief but the application of the rules to a UK permanent establishment of an overseas company can be difficult.
- Using a UK company addresses several of the pitfalls but cross-border intragroup arrangements can still raise challenges.
- HMRC is concerned about abuse of tax relief by companies artificially set up to claim when they have little or no employment or activity in the UK.
- It is important for genuine companies to be able to evidence the factual basis in support of their claim.
- Structuring and documenting arrangements correctly can have a significant impact on the support available.
The UK’s research and development (R&D) tax incentive regimes are designed to promote private sector investment in innovation. Small and medium-sized enterprises...
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