OT26050 | Capital Allowances: Research and Development Allowances: Redeterminations and Unitisations

Redeterminations

HMRC take the view that the liabilities that are settled by a redetermination were always present and thus the redetermination merely quantifies a pre-existing liability. RDA can therefore be claimed by the increasing interest party making a payment in respect of exploration conducted at an earlier date. This research was always incurred on behalf of the increasing interest party.

Unitisations

Unitisations are not so clear-cut and an RDA claim will depend on the terms and history of the particular agreement.