Research and Development tax credit
We have a client who is involved in developing Software principally in the simulation industry. Our client is engaged by a number of blue chip companies to carry out its work and the nature of the contracts are such that our client receives payment from them for the time incurred by its employees. The intellectual Property is retained by my client and no specific instructions are given to our client by its customers. We have claimed relief for R&D under the SME guidelines. However, whilst the Revenue accept that what our client does is R&D they are denying relief citing Section Schedule 20 Para 3(6) FA2000. From 1 April 2002 we should be able to get relief under the large companies legislation but we are looking at a period prior to this.
Can anyone help?