1082R&D expenditure of group companiesU.K.
(1)This section applies if—
(a)a company (“A”) incurs expenditure on making a payment to another company (“B”) in respect of activities contracted out by A to B,
(b)the activities would, if carried out by A, be research and development of A (taken together with A's other activities), and
(c)A and B are members of the same group at the time the payment is made.
(2)If the activities are undertaken by B itself, they are to be treated for the purposes of Chapters 3 and 5 (so far as it would not otherwise be the case) as research and development undertaken by B itself.
(3)If B makes a payment to a third party (“C”), any of the activities—
(a)contracted out by B to C, and
(b)undertaken by C itself,
are to be treated for the purposes of Chapters 3 and 5 (so far as it would not otherwise be the case) as research and development contracted out by B to C.
(4)For the purposes of this section A and B are members of the same group if they are members of the same group of companies for the purposes of Chapter 4 of Part 10 of ICTA (group relief).