The First-tier Tribunal could not consider a company’s appeal against an amendment by HMRC to a claim for R&D tax credits on the grounds of unfairness and unreasonableness on HMRC’s part.
The appellant company was incorporated in 2009 and developed and provided telecommunications equipment and software. The changing technology of such communications (from 2G to 3G to 4G) required continual development of its offering. It operated in a small, difficult market and cashflow could be difficult.
The company made its first research and development (R&)
