Gripple Ltd v Revenue & Customs Commissioners [2010] EWHC 1609 (Ch), [2010] All ER (D) 263 (Jun)
The purpose of para 5(2) of Schedule 20 to the Finance Act 2000 was not to expand the meaning of “staffing costs”, which had already been exhaustively defined in para 5(1), but rather to explain which staffing costs were to be treated as “attributable to relevant research and development”.
Paragraph 5(2) set out the circumstances in which expenditure attributable to research and development was to be treated as attributable to staffing costs, namely when it was “paid to, or in respect of, directors or employees directly and actively engaged in such research and development”.
