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Official guidance
Corporate Intangibles Research and Development Manual

CIRD81000 · R&D tax relief: conditions to be satisfied

  • CIRD81100 · Overview
  • CIRD81130 · Company a going concern
  • CIRD81160 · Total aid to project €7.5m or less (SME and vaccines schemes only)
  • CIRD81200 · Company subject to CT
  • CIRD81220 · Company as member of partnership
  • CIRD81300 · The definition of R&D for tax purposes
  • CIRD81350 · Production and distribution of goods and services
  • CIRD81400 · Relevant R&D
  • CIRD81450 · Allowable as a deduction in computing the profit
  • CIRD81470 · Subcontracted R&D
  • CIRD81500 · Categories of qualifying expenditure
  • CIRD81550 · Intellectual property (SME scheme only)
  • CIRD81600 · Minimum expenditure
  • CIRD81650 · Subsidies (SME scheme only)
  • CIRD81670 · Effect of notified State aid
  • CIRD81700 · Capital expenditure
  • CIRD81800 · SME scheme claims and time limits
  • CIRD81805 · Restriction of nominations and assignments
  • CIRD81900 · BIS Guidelines (formerly DTI Guidelines) (2004) - text
  • CIRD81910 · DSIT Guidelines (2023) - text
  • CIRD81920 · DSIT Guidelines - application to pharmaceuticals
  • CIRD81960 · BIS Guidelines (formerly DTI Guidelines) (2004) - application to software
  • CIRD81980 · Case Studies demonstrating R&D tax credit claims for software projects
  1. R&D tax relief: conditions to be satisfied: contents
  2. R&D tax relief: conditions to be satisfied: relevant R&D

CIRD81400 | R&D tax relief: conditions to be satisfied: relevant R&D

From HM Revenue & Customs · Corporate Intangibles Research and Development Manual

CTA09/S1042

Relevant research and development for a company is research and development:

  • related to a trade that the 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 includes, but is not limited to:

  • any R&D which may lead to or facilitate an extension of the trade, and

  • medical research that has a special relation to the welfare of workers employed in that trade; for example research into an occupational disease.

Medical research that has a special relation to the welfare of workers employed in a trade does not include research undertaken for the benefit of the community as a whole.

Medical research undertaken for the benefit of the community as a whole may, however, qualify as R&D that may lead to or facilitate an extension of the trade. For example, medical research undertaken by a drug company for the purpose of its trade may qualify because it is related to its trade of manufacturing drugs.

The carrying out of R&D is not necessarily a trade of itself. Generally a person must enter into contracts to provide goods or services to another person in return for a reward to be trading. Whether activities amount to a trade is considered at BIM20050 onwards.

HMRC may find that a company carries out R&D prior to commencing to trade. If the R&D is intended to be relevant to its trade then the R&D is relevant R&D. Pre-trading expenditure for SMEs is considered at CIRD90200 and for large companies at CIRD88000.

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