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Vaccine Research Limited Partnership v HMRC (and related appeal)

In Vaccine Research Limited Partnership v HMRC (and related appeal) (TC02491 – 12 February) the members of a Jersey limited partnership claimed research and development allowances for expenditure on vaccine research and development. They claimed loss relief totalling more than £192m. HMRC rejected the claims accepting that a Jersey company (N) which was a member of the partnership had paid a subcontractor (P) £14m on research and development but considering that the partnership had not been trading and that the other partners were not entitled to the allowances which they had claimed. The partners appealed contending that N had been working for the partnership as a contractor. The FTT reviewed the evidence in detail and allowed their appeals in part but rejected the majority of the partners’ claims for relief. Judge Williams held that only the £14m which N had paid to P could...

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