The R&D Project Which Never Was
At the end of July, Tax Policy Associates posted an update on the Dundee United FC R&D claim story, which included a copy of some claim documentation, which had been electronically signed by both the finance director at Dundee United and a director at ZLX.
The claim documentation was in relation to Dundee United’s period ended June 2022 and their claimed total R&D spend for the period was £1,383,042.44.
Of the three R&D projects included in the document, the one titled “The Development and Implementation of Research Informed Training Protocols to Enhance Sports Performance and Prevent Injury Relating to Changes in Total Physical Load on Professional Footballers” was by far the most expensive, as they claim to have spent £696,390.61 on this project alone, with £662,362.24 of “staffing costs” making up the bulk of the expenditure which included 12.5% of their entire players wage bill for the period.
The supporting technical narrative for this project was very clear that this project had started in July 2020 and was a collaboration between Dundee United and Abertay University.
Freedom Of Information
Following TPAL releasing the Dundee United claim documentation, Paul Malik a journalist at The Courier, had the quite frankly genius idea (I wish I had thought of it!) of submitting an FOIA request to Abertay University for all correspondence between the university and Dundee United between January 1 2020 and December 1 2022.
The results of this request were received in early September and make for some interesting reading, as the first email between the university and Dundee United is dated 10th Jan 2022.
What’s even more surprising is that the subject and content of the email make it very clear that at this point Dundee United and Abertay University weren’t already working together, as this email is a request for a meeting to discuss some research ideas, rather than the type of email you would expect had two parties been working together for the past 18 months.
In a follow up email, dated 2nd Feb 2022, one of the research ideas which are mentioned is:
“Load – what is it, why is it important and how do we measure it at DUFC. What are we doing in comparison to Rangers / Celtic / the rest?”
Yet, according to the Dundee United R&D claim documentation, both these organisations had collaboratively performed “extensive, investigative research” into this subject for nearly 2 years, which this email would seem to disprove.
The covering letter to the FOI request also confirms that in 2022 the project was just a proposal and never actually became a research project between Dundee United and Abertay University.
So, it seems that the R&D claim report, signed by both Dundee United and ZLX, contained some deliberate, misleading statements with regards to the largest project being claimed for.
Namely that it was a collaborative project between Dundee United and Abertay University, and that it had started in 2020.
If the report we’ve seen was submitted to HMRC, or a different version containing the same project, then that does look potentially like fraud.
Mr McCallion claims it wasn’t submitted. But has never explained why such a document was created and signed. And Dundee have never denied that the document was filed, despite its very damaging nature
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1moPaul Rosser the next piece has to be an analysis of football clubs, their latest cash balances & potential clawbacks from HMRC on R&D - we can then start placing some bets on which players may have to be sold!
Stamp duty land tax specialist at Blake Morgan
1moDan Neidle has published his exchange of emails with Stephen McCallion about this issue: https://www.linkedin.com/posts/danneidle_what-happened-when-i-asked-rd-tax-relief-activity-7382387278507139072-faSX
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1moThanks for highlighting Paul. Clearly the claim falls down on many of the key conditions of the scheme
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1moGreat article Paul Rosser. Well done for highlighting the inconsistencies and well done too to Paul Malik for obtaining the correspondence/information.
Stamp duty land tax specialist at Blake Morgan
1moWhat an extraordinary story! Well done Paul Malik for following this up. It was rather inspired to make a Freedom of Information request to the university.