In Quinn (London) Ltd v HMRC [2021] UKFTT 437 (TC) (27 October 2021) the First-tier Tribunal (FTT) decided in principle that the company was not prevented from claiming relief for research and development (R&D) costs under the scheme for SMEs. Specifically the FTT rejected HMRC’s argument that the expenditure was subsidised by the company’s clients.
Quinn was a construction company which operated across a number of sectors including commercial residential education and heritage. It tendered for work and for each project for which it was successful entered into a fixed price contract based on standard industry terms. In the course of various projects the company incurred R&D expenditure. For example in renovating a 17th century listed mansion it devised methods for replacing load-bearing timber joists with steel supports and adapted a micro-pile system to allow a lift to be installed. It claimed...
