Our client company made a claim for R&D allowances for the year ended 31st December 2003. They used sub-contractors (individuals, not organisations)for some of the R&D work, and a couple of the invoices include the words "Market research on available infrared cameras".
The inspector wants to disallow the part relating to market research, on the basis that SSAP 13 excludes market research from activities which amount to R&D.
It occurs to me that there can be (at least) two different types of market research:
- research the market for the products that you're developing (ie your sales market), and
- research the market to discover what specialised products are available which might help you in your work (ie your purchase market).
It seems to me that there MIGHT be a fundamental difference between the two.
Market research is not defined in SSAP13.
Has anyone got experience of arguing this with the Revenue, or am I maybe attempting to dance on the head of a pin?
Brian
