ACCA welcomes the opportunity to comment on the proposals issued by HMRC.
We have consulted our members through surveys and expert interviews and their views are represented in the following.
The draft guidance does not appear to be consistently written with a specific audience or objective in mind. In our view, further consideration of its purpose is required for the guidance to be as useful as it can be.
Collaboration via a digitised iterative process based on input from the companies and HMRC specialist R&D team would be more fitting for the R&D sector and align the customers expectations. Are there any lessons to be learned from global competitors for R&D activity?
Ultimately, the success of the changes will be dependent on HMRC’s capacity to implement in a timely manner.
To read the response in full, please download the consultation response document.