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The SME Scheme & Group Structures

 
Lindsay Pentelow Tax Partner in Mazars explores some of the different contractual relationships within a group which can either block or create access to SME R&D relief
 
Since 1 August 2008 the SME R&D relief can create a tax underwriting for qualifying R&D spend of 49p in the £ (28% x 175%) and although the cash payment for loss-making companies is limited to 24.5p in the £ (14% x 175%) the relief can provide one way or another a very significant cash flow benefit to companies.
 
Like all cash generation this is even more attractive in hard times than in good. Furthermore whilst in the medium term the Treasury will need to increase tax receipts it is difficult to envisage R&D reliefs being restricted. The encouragement...
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