The government published its consultation on the introduction of an ‘above the line’ (ATL) credit for R&D on 27 March 2012. There is a lot of work to do before the regime is launched but the ATL credit will be a good thing for UK R&D. It is however a shame that SMEs look like being excluded.
At present CTA 2009 Part 13 provides for R&D relief by way of an increased deduction in computing taxable profits. A loss-making large company does not have the ability to receive a payable credit. The fact that this is principally an extra deduction given in computing the tax liability means that it is accounted for in the taxation line in the accounts. The problem that this...