Biotech breaks most of the assumptions built into small-company accounting. There is no revenue for years, the largest costs are paid to other people, the share register usually includes a university, and the difference between a good and a bad R&D claim is six figures rather than four.
The question that decides most of it is deceptively simple: who commissioned the research? Under the merged scheme the company that intended or contemplated the R&D claims it — and HMRC means a specific appreciation of what would be done, not general awareness that somebody was doing science. For a company whose spend runs through CROs and academic partners, that is the whole argument.








