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

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December 19, 2024

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

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