CIRD97050 - R&D tax relief: avoidance: introduction
This section addresses the question of avoidance within the
R&D regime. With any system that provides tax incentives there
will be those who seek to exploit them by artificial means either
without actually carrying out the required activities, or by doing
so on a smaller scale than claimed. It is necessary to be alert to
avoidance attempts, but without this colouring the approach to the
vast majority of genuine claimants.
If you suspect that you have identified artificial avoidance
arrangements please notify Business Tax (Technical) at an early
stage, even if you think there may be no available challenge. There
is further guidance at:
Other approaches to challenging avoidance
It should not be assumed that any challenge to avoidance
would be confined to the specific anti avoidance legislation. There
may be challenges derived from accountancy, other tax law, or
challenges to the factual accuracy or the correct analysis of what
has been reported to have taken place.
