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Pyreos v HMRC

In Pyreos v HMRC [2015] UKFTT 123 (18 March 2015) the FTT found that a substantial shareholder was a venture capital company so that relief for R&D expenditure applied.

The appeals related to two claims by Pyreos for tax relief on expenditure on research and development by ‘small and medium-sized enterprises’ (CTA 2009 s 1119). As more than 25% of the share capital of Pyreos was held by Siemens Technology Accelerator (STA) the relief could only be available if STA was a ‘venture capital company’ (VCC) as this would mean that Pyreos was not a ‘partner enterprise’ for the purpose of the provision.

The FTT observed that the overriding principle of the provision was that it was intended to benefit genuinely autonomous companies. The FTT added that it had not been referred to any definition of VCC. It construed it as a ‘company whose interest is...

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