“…There is no dispute between the parties that Barclays Mercantile Business Finance Ltd v Mawson (Inspector of Taxes) [2004] UKHL 51, [2005] 1 AC 684, [2005] STC 1 (“BMBF”) provides the correct starting point. That was a case in which the House of Lords held that, on the facts, the taxpayer was entitled to capital allowan…”
“… Agreement. It raised serious arguments based on the decisions of the House of Lords and the Supreme Court in Barclays Mercantile Business Finance Ltd v Mawson [2005] STC 1 and HMRC v Tower MCashback [2011] UKSC 19 to the effect that the whole £120m had been expended “on” research. All that the FtT and subsequently the Upper Tribu…”