Mark Middleditch (Allen & Overy) provides this month’s update, including: the UT decision in The Vaccine Research Limited Partnership; the G20 meeting of finance ministers and BEPS; the targeting of the quoted Eurobond exemption loophole; and the latest HMRC guidance on additional Tier 1 capital for foreign banks
In The Vaccine Research Limited Partnership and others v HMRC [2014] UKUT 0839 (TC) (reported in Tax Journal 12 September 2014) the Upper Tribunal (UT) has restricted entitlement to research and development (R&D) allowances where bank debt was used to leverage the expenditure for which the relief was claimed.
In the case a partnership entered into a contract with an R&D contractor. The contractor then entered into a sub-contract...
