02 September 2014

UT Decision: Vaccine Research Limited Partnership v HMRC

Capital allowances – expenditure on research and development – whether partnership trading – quantum of expenditure incurred on research and development – whether trade conducted on a commercial basis – location of partnership’s trade – income tax relief for interest incurred on borrowings to fund partnership capital – deductibility of fee incurred by partnership in consideration for services – whether wholly and ordinarily incurred for the purpose of the partnership’s trade

Kevin Prosser QC, David Yates & Zizhen Yang, instructed by HMRC, for the Respondents.

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