Part 13Additional relief for expenditure on research and development
Chapter 6Chapters 2 to 5: further provision
1081Insurance companies treated as large companies
1
This section applies if an insurance company—
a
carries on life assurance business in an accounting period, and
b
is a small or medium-sized enterprise in the period.
2
For the purposes of F3Chapter 2 the company is to be treated as if it were not such an enterprise in the period.
F43
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F51082R&D expenditure of group companies
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F61083Refunds of expenditure treated as income chargeable to tax
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1084Artificially inflated claims for relief or tax credit
1
To the extent that a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it is to be disregarded for the purposes mentioned in subsection (2).
2
Those purposes are—
a
determining for an accounting period relief to which a company is entitled under F1Chapter 2 , and
b
determining for an accounting period R&D tax credits to which a company is entitled under Chapter 2.
3
Arrangements are entered into wholly or mainly for a “disqualifying purpose” if their main object, or one of their main objects, is to enable a company to obtain—
a
relief under F2Chapter 2 to which it would not otherwise be entitled,
b
relief under F2Chapter 2 of a greater amount than that to which it would otherwise be entitled,
c
an R&D tax credit under Chapter 2 to which it would not otherwise be entitled, or
d
an R&D tax credit under Chapter 2 of a greater amount than that to which it would otherwise be entitled.
4
In this section “arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable.