R&D Tax Reliefs: New Contracting Out Rules and Overseas Restrictions – Draft Guidance

The Association of Taxation Technicians (ATT) has submitted comments on draft guidance relating to 'R&D tax reliefs: new contracting out rules and overseas restrictions'.

This draft guidance sets out more detail regarding HMRC's interpretation of new rules around contracted out R&D activities and overseas expenditure which take effect from 1 April 2024.

Overall, we found the draft guidance to be very helpful in addressing what are relatively complex areas of the proposed new R&D tax relief regime. In particular, we welcome the practical focus and extensive use of examples. However, we believe it is a shame that this guidance is only being published now, less than two months before the new regime is due to take effect.