In Realbuzz Group Ltd v HMRC [2025] UKFTT 493 (TC) (1 May) the FTT allowed a software company’s appeal against a discovery assessment. The assessment was made to withdraw R&D relief but the FTT held that the statutory restriction for ‘available information’ applied so that the assessment was invalid.
The company’s amended return for its accounting period to 30 April 2020 included a claim for R&D relief which was accompanied by an R&D report including a number of different projects. Its return for the year to 30 April 2021 also included an R&D relief claim. HMRC opened an enquiry into the return for 2021 and in 2023 issued a closure notice denying the R&D claim. It raised an assessment for 2020 on the basis that some of the 2021 projects had begun in 2019 and so there would have been inaccuracies in the...
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In Realbuzz Group Ltd v HMRC [2025] UKFTT 493 (TC) (1 May) the FTT allowed a software company’s appeal against a discovery assessment. The assessment was made to withdraw R&D relief but the FTT held that the statutory restriction for ‘available information’ applied so that the assessment was invalid.
The company’s amended return for its accounting period to 30 April 2020 included a claim for R&D relief which was accompanied by an R&D report including a number of different projects. Its return for the year to 30 April 2021 also included an R&D relief claim. HMRC opened an enquiry into the return for 2021 and in 2023 issued a closure notice denying the R&D claim. It raised an assessment for 2020 on the basis that some of the 2021 projects had begun in 2019 and so there would have been inaccuracies in the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
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