CIRD75300 | VRR: qualifying expenditure: on direct R&D
From HM Revenue & Customs · Corporate Intangibles Research and Development Manual
FA02/SCH13/PARA3 - 5, FA00/SCH20/PARA2, PARAS 5, 6, & 8
A qualifying R&D activity is R&D relating to certain specified diseases CIRD76000.
Relevant R&D is R&D:
related to a trade that a company carries on, or
from which it is intended that a trade to be carried on by the company will be derived.
R&D related to a trade carried on by a company includes any R&D which may lead to or facilitate an extension of the trade.
Qualifying expenditure on direct R&D is expenditure incurred by a company on:
for a qualifying R&D activity directly undertaken by the company and that satisfies the following conditions:
the qualifying R&D activity must relevant R&D in relation to the company,
the expenditure must not be capital expenditure and it must not be subsidised,
the company must not incur the expenditure in carrying out activities contracted out to it by somebody else.
A company’s R&D expenditure is subsidised to the extent that its cost is met by another person. Subsidised expenditure is not excluded from the relief entirely; you calculate the VRR on the amount net of the subsidy. However, if the R&D project is funded even in part by a notified State aid (typically, a government grant) then no VRR is given. (For this purpose only, SME tax relief and SME tax credit are not treated as State aids).