A company was only entitled to research and development relief on part of its expenditure on projects in respect of which the relief was claimed. 

Summary

A company was only entitled to research and development (R&D) relief on part of its expenditure on projects in respect of which the relief was claimed. 

Background

The appellant company's original corporation tax returns for 2009 and 2010 were originally submitted without claims for R&D relief. On 20 April 2011, the appellant submitted amended returns claiming enhanced R&D relief. On 26 April 2011, the appellant filed an R&D report prepared by MSC Business Innovation (Development) Limited ('MSC') in support of the R&D claims.

The appellant's claims were made under the small and medium-sized enterprise scheme claiming additional enhanced expenditure of 75%. The following projects were