C1Part 3Trading income
F1CHAPTER 6ATrade profits: R&D expenditure credits
Pt. 3 Ch. 6A inserted (with effect in accordance with Sch. 15 para. 27 of the amending Act) by Finance Act 2013 (c. 29), Sch. 15 para. 1
Group companies
104WR&D expenditure of group companies
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 this Chapter (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 this Chapter (so far as it would not otherwise be the case) as research and development contracted out by B to C.
Pt. 3 modified (1.1.2010) by Northern Rock plc (Tax Consequences) Regulations 2009 (S.I. 2009/3227), regs. 1, 4(1)