ÀÏ˾»úÎçÒ¹¸£Àû

If there is a contract between two persons for R&D activities to be carried out by one of them for the other, the work has been 'subcontracted' or 'contracted out'. Where the necessary conditions are met, R&D tax relief may be available to a company which has subcontracted work out to another person or, in more limited cases, to a company to which activities have been subcontracted.

The rules determining where relief is available for subcontracted R&D have been substantially amended (and simplified) for accounting periods beginning on or after 1 April 2024¹. This article deals with the revised rules. For the rules which applied before April 2024, see D1.414.

Under the revised rules, where a customer company contracts out R&D to a third party contractor, the R&D tax relief stays with the customer and not the contractor unless the customer is an ineligible company or is not subject to UK tax, in which case, the contractor will be able to claim relief. If a contractor is contracted to do work which is not, or