UK: Anti-abuse rule applied to deny “refreshed” losses, taxpayer’s claim qualified under small and medium-sized enterprise R&D regime
Reports on two recent decisions of the First-tier Tribunal
The KPMG member firm in the UK prepared reports on two recent decisions of the First-tier Tribunal:
- The court held that the anti-abuse rule under Part 14B Corporation Tax Act (CTA) 2010 applied to deny the taxpayer the use of “refreshed” carry-forward losses. Read a December 2024 report
- The court held that the taxpayer’s research and development (R&D) activities were not “subsidized” or “subcontracted” and thus the taxpayer’s claim qualified under the small and medium-sized enterprise (SME) R&D regime. Read a December 2024 report