Defending Claims

Claims are submitted within the company's corporation tax computation and there is a window during which HMRC may raise an enquiry (formal or informal) into your claims.  Work to support clients when an enquiry is raised can range from written correspondence to telephone conversations and meetings with HMRC, sometimes spanning a full day-long session. 

Case study - HMRC enquiry and independent review

We have worked with a small innovative company specialising in the delivery of online high quality music for a number of years now.  HMRC raised an enquiry into their claim in 2012, focusing primarily on activities of the business and challenging the eligibility of their work.  We worked closely with the client in responding to HMRC written queries, participating in telephone calls with the Inspector to provide additional detail and finally making a request for formal independent review of the case before moving on to the Tax Tribunal for appeal.  HMRC carried out an independent review following our request and closed the enquiry with no adjustments to the claim.  The business received a significant cash credit and has gone on to make further successful claims for recent years.

Case study - HMRC enquiry

We worked with a large international energy and utilities business making first-time claims for part of their UK business.  This included significant claims on renewable energy and wind farms.  HMRC raised an enquiry in relation to these claims and we worked with the client to respond to their queries.  The focus of the enquiries related to the eligibility of the work.  A key part of any claim is working with the client's technical personnel to educate them on the meaning of "R&D" for tax purposes and to thoroughly explore the BIS Guidelines which provide the key criteria with those technical personnel.  This enables them, as the "competent professionals", to make assessments on specific projects and activities, discussing these in detail with us to understand where the boundaries of eligibility for each project/activity end.  We supported the client technical personnel in discussing specific projects with HMRC during a series of meetings at the client premises with a number of attendees from HMRC, including their CRM, specialist Inspector and local Inspector.  The outcome was again successful with the enquiry being closed shortly afterwards, with no adjustments being made to the original claims.