Commentary

D1.466 Artificially inflated claims for relief

Corporate tax
Corporate tax | Commentary

D1.466 Artificially inflated claims for relief

Corporate tax | Commentary

Vaccine research relief—special situations

D1.466 Artificially inflated claims for relief

The provisions in this article apply to large companies (for expenditure incurred before 1 April 2017) and SMEs (for expenditure incurred before 1 April 2012).

To the extent that a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it is to be disregarded in determining for an accounting period:

  1.  

    (a)     the deduction to which a company is entitled in respect of vaccine research expenditure (see D1.455, 456); and

  2.  

    (b)     the R&D tax credits (for expenditure incurred before 1 April 2012) to which it is

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