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Gripple Ltd v HMRC

 

Business Tax: Research and Development

 

In Gripple Ltd v HMRC (Ch D – 30 June) a company (G) claimed that certain payments which it had made to an associated company (L) were ‘staffing costs’ within what is now CTA 2009 s 1123 and qualified for tax relief as expenditure on research and development.

HMRC rejected the claim and G appealed contending that the payments should be treated as emoluments of its controlling director (F).

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