Aiglon Consulting

This Practice Note is about the research and development (R&D) tax relief for R&D-intensive loss-making SMEs for accounting periods beginning on or after 1 April 2024. It explains the conditions for claiming this relief and additional deductions and tax credits available. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains how to calculate a company's profits eligible for relief under the post-1 July 2016 patent box rules. The Practice Note sets out the eight-step process involved and examines key issues, including the streaming of relevant IP income (RIPI) and deductions for routine returns and marketing assets returns. It also covers the application of the R&D fraction, which is applied to meet the BEPS requirement that patent box benefits be linked to R&D levels. It concludes by describing how patent box relief is given. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains what a company can do with a relevant IP loss (RIPL). A company in the early stages of IP developments may have a RIPL rather than relevant IP profits, as a result of its patent box calculation and will not benefit from patent box relief. Instead, the company must set off the RIPL against other of its, or its group’s, profits for the current or future accounting periods. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note sets out the key features of the patent box regime, an elective regime providing for an effective 10% rate of corporation tax on worldwide profits attributable to qualifying patents and similar intellectual property rights. It considers the meaning of qualifying IP rights; the development condition; a qualifying company; an exclusive licence; and a group. It covers elections and how the regime applies to partnerships and cost-sharing arrangements. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note sets out the conditions that must be met by a company's expenditure for it to qualify for research and development (R&D) tax relief for the purposes of the merged R&D expenditure credit scheme (merged RDEC) and the enhanced R&D-intensive scheme (ERIS), which apply for accounting periods beginning on or after 1 April 2024. It discusses the requirement that the expenditure must be revenue (and not capital) in nature, the specified categories of qualifying expenditure, the rules for contracted out R&D and the restrictions on relief for overseas expenditure. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note sets out the numerous conditions that must be met by a company's expenditure for it to qualify for R&D tax relief. It discusses the requirement that the expenditure must be revenue (and not capital) in nature and related to the company’s trade, the specified categories of qualifying expenditure and the particular rules relating to subsidised expenditure and sub-contracted R&D. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains the R&D expenditure credit (RDEC) which, from 1 April 2016, replaced the enhanced deduction by way of large company R&D relief. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains the meaning of research and development (R&D) for the purposes of R&D tax relief for companies. Very broadly, R&D for tax purposes takes place within a project that seeks to achieve an advance in science or technology. This note also provides details of when R&D starts and when R&D ends, with particular reference to the production of prototypes. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note describes the R&D relief available to companies that are small or medium-sized enterprises (SMEs) by way of additional deduction in computing profits subject to corporation tax. It sets out the definition of a SME and describes when a SME is entitled to an additional deduction. Alternatively, loss-making SMEs may surrender the qualifying R and D element of their trading loss for a payable tax credit. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains the payable R&D tax credit available to companies that are SMEs. It sets out how the credit is calculated by reference to the surrenderable loss, the possible restrictions on the credit and the claim process. The note then compares the relative benefits for SMEs of claiming an immediately payable tax credit as opposed to carrying forward (or surrendering by way of group relief) the potentially more valuable additional deduction. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains the merged research and development expenditure credit (merged RDEC). It provides tax relief for corporate expenditure on R&D and applies for accounting periods beginning on or after 1 April 2024. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.