The Vaccine Research Limited Partnership and Patrick Lionel Vaughan v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v The Partnership and Mr Vaughan: [2014] UKUT 0389 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Sales and Judge Ghosh on 2 September 2014.
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.Capital allowances – expenditure on research and development – whether partnership trading – quantum of expenditure incurred on research and development – whether trade conducted on a commercial basis – location of partnership’s trade – income tax relief for interest incurred on borrowings to fund partnership capital – deductibility of fee incurred by partnership in consideration for services – whether wholly and ordinarily incurred for the purpose of the partnership’s trade.