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Corporate Intangibles Research and Development Manual
Publication Date: 2024
Publisher: Bloomsbury Professional
Copyright: 2024 Crown
Corporate Intangibles Research and Development Manual
Corporation Tax and the taxation of intangible assets, remediation of contaminated land, vaccines research relief and tax credits for research & development.
Last Update: 28th November 2024
Contents
- Close sectionCIRD00500: Introduction to manual
- Close sectionCIRD10000: Intangible assets regime
- Close sectionCIRD10100: Intangible assets: introduction
- CIRD10101: Background
- CIRD10105: Chronology of CTA09 reforms
- CIRD10110: Overview of CTA 2009, Part 8 tax rules
- CIRD10115: Link with accountancy
- CIRD10116: Simple example of taxation entries derived from figures in accounts
- CIRD10120: Capital versus revenue distinction no longer crucial
- CIRD10125: Expenditure linked to assets and to non capitalised expenditure
- CIRD10130: Disallowance of sums charged in the accounts
- CIRD10140: Commencement of new regime: existing assets
- CIRD10145: Assets outside FA02 rules: location of guidance
- CIRD10150: Royalties from new or existing assets
- CIRD10160: Related parties
- CIRD10170: Reinvestment relief
- CIRD10175: Reinvestment relief: transitional arrangements
- CIRD10180: Reinvestment relief: example
- CIRD10190: Groups of companies
- CIRD10200: International aspects
- CIRD10210: Finance leasing
- CIRD10220: Fungible assets
- CIRD10230: Avoidance
- CIRD10240: Valuation issues
- Close sectionCIRD11000: Intangible assets within CTA 2009, Part 8: asset conditions
- CIRD11010: Introduction
- CIRD11030: General intention
- CIRD11035: Legislative approach
- CIRD11050: Outline
- CIRD11070: Goodwill
- CIRD11100: Assets other than goodwill: outline
- CIRD11120: Meaning of intangible asset: accountancy test
- CIRD11135: Importance of distinction between goodwill and intangible asset
- CIRD11150: Meaning of intangible asset: intellectual property
- CIRD11170: Requirement that asset must be fixed
- CIRD11175: Options in respect of intangible fixed assets
- Close sectionCIRD11500: Intangible assets within CTA 2009, Part 8: FA02 rule: general conditions
- CIRD11505: Introduction
- CIRD11520: Outline
- CIRD11530: Flowcharts
- CIRD11600: Asset created by company
- CIRD11610: Asset acquired from an unrelated party
- CIRD11625: Asset acquired from a related party in qualifying circumstances: outline
- CIRD11630: Asset acquired from related party in qualifying circumstances: asset within CTA 2009, Part 8 in hands of transferor
- CIRD11640: Asset acquired from a related party in qualifying circumstances: asset acquired by a related party from an independent third party
- CIRD11650: Asset acquired from a related party in qualifying circumstances: asset created on or after 1 April 2002
- CIRD11655: Asset acquired on or after 1 July 2020
- CIRD11660: Asset acquired on or after 1 April 2002: asset transfers within TCGA 1992, s 139 or S140A
- CIRD11665: Time when asset created or acquired: scope
- CIRD11670: Time when asset treated as created or acquired: expenditure incurred rule
- CIRD11675: Time when asset treated as created or acquired: exceptions to expenditure incurred rule: overview
- CIRD11678: Time when asset treated as created or acquired: whether expenditure on creation or on enhancement of asset
- CIRD11680: Time when asset treated as created or acquired: exceptions to expenditure incurred rule: goodwill
- CIRD11685: When asset treated as created or acquired: exceptions to expenditure incurred rule: assets other than goodwill not qualifying for capital allowances
- CIRD11688: Time when asset treated as created or acquired: exceptions to expenditure incurred rule: example - licence granted by a related party before 1 July 2020
- CIRD11690: When asset treated as created or acquired: when expenditure is treated as incurred
- Close sectionCIRD11700: Intangible assets within CTA 2009, Part 8: time test: exceptions
- CIRD11705: Royalties - outline
- CIRD11710: Royalties - definition of royalties
- CIRD11720: Royalties - general
- CIRD11725: Royalties - examples
- CIRD11730: Assets already within income regime - introduction
- CIRD11740: Assets already within income regime - certain telecommunications assets
- CIRD11750: Assets already within income regime - syndicate capacity at Lloyd's
- CIRD11760: Fungible assets - introduction
- CIRD11760
- CIRD11780: Fungible assets - additions to existing holdings: anti-avoidance rule
- Close sectionCIRD12000: Core computational rules: accounting
- CIRD12010: Introduction
- CIRD12020: Allocation of amounts to periods of account
- CIRD12030: Subject to any adjustments required
- CIRD12210: Terminology used in legislation and guidance
- CIRD12220: Period for which entries taken into account for tax: practical effect
- CIRD12230: Period for which entries taken into account for tax: statute
- CIRD12240: Entries within new rules: link with intangible assets: introduction
- CIRD12250: Entries from which deductible debits derived: link between accounting entries and intangible assets within new rules
- CIRD12260: Entries from which deductible debits derived: exclusion of expenditure on tangible assets
- CIRD12270: Entries from which deductible debits derived: list of types
- CIRD12280: Entries from which taxable credits derived: list of types
- CIRD12300: Change of accounting policy
- CIRD12310: Change of accounting policy: disaggregation of assets
- CIRD12320: Disaggregation of assets: fixed rate write down elections
- Close sectionCIRD12500: Core computational rules: deductible debits: general matters and adjustments for tax purposes
- CIRD12510: Introduction
- CIRD12530: Expenditure charged to the profit and loss account as it accrues
- CIRD12550: Abortive expenditure on realisation
- CIRD12560: Accounting losses in respect of the reversal of previous accounting gains
- CIRD12580: Mostly relevant where expenditure written off as incurred
- CIRD12600: Disallowance of expenditure: entertaining and gifts
- CIRD12610: Disallowance of expenditure: criminal payments
- CIRD12620: Cars - restriction of hiring costs
- CIRD12630: Disallowance of expenditure: employer-financed retirement benefit schemes
- CIRD12640: Deferral of deduction: payment of pension contributions delayed
- CIRD12650: Deferral of deduction: payment of remuneration delayed
- CIRD12660: Deferral of deduction: payment of royalties to related party delayed
- CIRD12670: Debt impairment losses and bad debts
- Close sectionCIRD12700: Core computational rules: deductible debits: relief for capitalised expenditure on an intangible asset
- CIRD12710: Introduction
- CIRD12720: Tax cost
- CIRD12725: Grants received
- CIRD12730: Acquired as part of a larger bargain: outline
- CIRD12735: Acquired as part of a larger bargain: GAAP acquisition accounting
- CIRD12740: Acquired as part of a larger bargain: just and reasonable apportionment
- CIRD12745: Deemed to be acquired at book value
- CIRD12755: Accounts-based relief: general
- CIRD12760: Accounts-based relief: where tax and accounting values diverge: period expenditure first capitalised
- CIRD12770: Accounts-based relief: where tax and accounting values diverge: period after expenditure first capitalised
- CIRD12775: Accounts-based relief: where tax and accounting values diverge: Lloyd's syndicate capacity
- CIRD12780: Accounts-based relief: market value acquisition of asset not on balance sheet
- CIRD12790: Accounts-based relief: capitalisation of asset at valuation
- CIRD12795: Accounts-based relief: part realisation of asset
- CIRD12905: Fixed rate relief: general
- CIRD12910: Fixed rate relief: computation
- CIRD12920: Fixed rate relief: debits following part realisation
- Close sectionCIRD13000: Core computational rules: taxable credits
- CIRD13010: Introduction
- CIRD13020: Receipts recognised as they accrue: general
- CIRD13030: Receipts recognised as they accrue: grants
- CIRD13050: Revaluation of intangible assets
- CIRD13060: Revaluation of intangible assets: example
- CIRD13080: Negative goodwill' referable to intangible assets
- CIRD13090: Accounting gains reversing previous accounting losses
- Close sectionCIRD13200: Core computational rules: realisation of assets
- Close sectionCIRD13500: Core computational rules: CT computation
- CIRD13510: General
- CIRD13520: Intangible assets used for a trade or property business
- CIRD13530: Intangible assets not used for a trade or property business
- CIRD13540: Intangible assets not used for a trade or property business: set-off of non-trading loss against total profits
- CIRD13550: Intangible assets not used for a trade or property business: surrender of non-trading loss as group relief
- CIRD13560: Intangible assets used for life assurance business
- Close sectionCIRD20000: Reinvestment relief: general matters and conditions to be satisfied
- CIRD20010: Introduction
- CIRD20015: Provisional entitlement to relief
- CIRD20020: Outline of detailed guidance
- CIRD20025: Comparison with CG roll-over relief
- CIRD20035: By asset realised: chargeable intangible asset requirement: general
- CIRD20040: By asset realised: chargeable intangible asset requirement: telecommunications assets and Lloyd's syndicate capacity
- CIRD20050: By asset realised: assets within CG code
- CIRD20060: On realisation: proceeds test
- CIRD20070: On realisation: exclusion of deemed realisations
- CIRD20080: On realisation: part realisation of asset to related party
- CIRD20105: By new asset: summary
- CIRD20110: By new asset: time limits for reinvestment
- CIRD20120: By new asset: expenditure must be capitalised
- CIRD20130: By new asset: must be ‘chargeable intangible asset’
- CIRD20140: By new asset: deemed acquisition: reacquisition of the same asset
- CIRD20150: Form of claim
- Close sectionCIRD20200: Reinvestment relief: computation
- CIRD20205: Introduction
- CIRD20210: Old asset chargeable intangible asset: complete realisation of asset: proceeds fully reinvested
- CIRD20220: Old asset chargeable intangible asset: complete realisation of asset: proceeds not fully reinvested
- CIRD20230: Old asset chargeable intangible asset: asset partly realised: remainder of asset realised after earlier part realisation
- CIRD20235: Old asset chargeable intangible asset: asset partly realised: remainder of asset realised after earlier part realisation: examples
- CIRD20240: Old asset within CG code
- CIRD20270: Interaction with CG roll-over relief: circumstances where roll-over relief no longer available
- CIRD20280: Interaction with CG roll-over relief: flowchart
- CIRD20285: Interaction with CG roll-over relief: tabular summary
- CIRD20290: Interaction with CG roll-over relief: hybrid claims
- CIRD20295: Interaction with CG roll-over relief: hybrid claims: examples
- Close sectionCIRD20400: Reinvestment relief: groups of companies
- CIRD20405: General
- CIRD20410: Expenditure on new assets by another group member
- CIRD20420: Expenditure on shares of company which becomes group member: qualifying conditions
- CIRD20430: Expenditure on shares of company which becomes group member: further rules
- CIRD20440: Expenditure on shares of company which becomes group member: examples
- CIRD20460: Relief against taxable credit on degrouping
- CIRD20470: Relief against reallocated taxable credit on degrouping
- CIRD20480: Relief against CG degrouping charge
- Close sectionCIRD25000: Intangible assets excluded from CTA 2009, Part 8
- CIRD25010: Introduction
- CIRD25015: Partial exclusion of asset: apportionment
- CIRD25025: Assets outside FRS 102 s18: general
- CIRD25030: Assets outside FRS 102 s18: rights over tangible assets
- CIRD25040: Assets outside FRS 102 s18: oil licences
- CIRD25050: Assets outside FRS 102 s18: financial assets
- CIRD25060: Assets outside FRS 102 s18: rights in companies, trusts and partnerships
- CIRD25070: Assets held for non-qualifying purposes
- CIRD25090: Assets held for the purposes of activities outside the charge to CT
- CIRD25095: Assets for which capital allowances previously made
- Close sectionCIRD25100: Intangible assets excluded from CTA 2009, Part 8 as special tax rules apply
- CIRD25105: Introduction
- CIRD25110: Except as regards royalties: overview
- CIRD25115: Except as regards royalties: assets held for life assurance business
- CIRD25120: Except as regards royalties: assets held for mutual trade or business
- CIRD25130: Except as regards royalties: master versions of films and sound recordings
- CIRD25140: Except as regards royalties: computer software treated as part of cost of related hardware
- CIRD25145: Websites for which capital allowances have been claimed
- CIRD25150: Research and development and other computer software: overview
- CIRD25160: Research and development: approach
- CIRD25170: Research and development: computational provisions which continue to apply
- CIRD25180: Election in respect of capital expenditure on computer software: approach and procedure
- CIRD25190: Election in respect of capital expenditure on computer software: computational consequences
- Close sectionCIRD27000: Leasing of intangible assets
- CIRD27010: Outline
- CIRD27020: Accountancy background
- CIRD27030: Lessees: scope
- CIRD27035: Lessees: computational consequences
- CIRD27050: Lessors: general
- CIRD27060: Lessors: exclusions
- CIRD27070: Lessors: computational rules: general
- CIRD27080: Lessors: computational rules: change of use
- CIRD27090: Text of financial instrument SI2002/1967
- Close sectionCIRD30000: Intangible assets: GAAP
- CIRD30010: Summary of guidance
- CIRD30020: Definition
- CIRD30055: Role of
- CIRD30065: Conformity with: is required for CTA 2009, Part 8
- CIRD30070: Conformity with: consequences where not followed
- CIRD30080: Conformity with: recourse to consolidated accounts
- CIRD30090: Conformity with: nature of accounting judgements
- CIRD30105: Conformity with: circumstances where accounts may not do so
- CIRD30110: Conformity with: accounts not intended to conform
- CIRD30120: Conformity with: accounts intended to conform but may not do so: general
- CIRD30130: Conformity with: accounts intended to conform but may not do so: choosing cases for enquiry
- CIRD30140: Conformity with: need to involve HMRC advisory accountants
- Close sectionCIRD30500: Intangible assets: notes on accounting practice
- CIRD30505: Introduction
- CIRD30530: Definition and when to capitalise: intangible assets other than goodwill
- CIRD30535: Definition and when to capitalise: goodwill
- CIRD30536: Acquisition of a business
- CIRD30537: Fair values on acquisition of a business
- CIRD30540: Amortisation
- CIRD30550: Impairment
- CIRD30580: Revaluations
- CIRD30650: Internally generated assets
- Close sectionCIRD40000: Intangible assets: groups
- Close sectionCIRD40200: Intangible assets: groups: tax-neutral transfers
- Close sectionCIRD40500: Intangible assets: groups: degrouping
- CIRD40505: Overview
- CIRD40510: Outline of rules
- CIRD40520: General conditions for adjustment
- CIRD40530: Associated companies leaving group together
- CIRD40540: Associated companies leaving group: subsequent charge
- CIRD40545: When is there a relevant connection between groups?
- CIRD40550: Principal company becoming member of another group
- CIRD40560: Subsequent restoration of degrouping adjustment
- CIRD40570: Exception for degroupings qualifying for Substantial Shareholdings Exemption - overview
- CIRD40575: Exception for degroupings qualifying for Substantial Shareholding Exemption - requirements
- CIRD40580: Exclusion of commercial mergers
- CIRD40590: Exclusion of exempt distributions
- CIRD40600: Companies not members of same group at time asset transferred
- CIRD40610: Examples of degrouping computation
- CIRD40705: Reallocation between group members: candidates
- CIRD40710: Reallocation between group members: relevant time and relevant group
- CIRD40720: Unpaid degrouping charge: recovery from others: candidates
- CIRD40730: Unpaid degrouping charge: recovery from others: definitions
- CIRD40740: Unpaid degrouping charge: recovery from others: procedures
- CIRD40750: Intra group payments for reinvestment relief and reallocation of taxable credit
- Close sectionCIRD42000: Intangible assets: company reorganisations
- CIRD42010: Overview
- CIRD42020: Transfer of business without consideration: general
- CIRD42025: Transfer of business without consideration: conditions
- CIRD42030: Transfer of UK trade between EU residents: general
- CIRD42035: Transfer of UK trade between EU residents: further conditions
- CIRD42040: Transfer of foreign permanent establishment from UK to a non resident company: deferral of charge
- CIRD42045: Transfer of foreign permanent establishment from UK to a non resident company: amount of charge deferred
- CIRD42050: Transfer of foreign permanent establishment from UK to a non resident company: when deferral ceases
- CIRD42055: Transfer of foreign permanent establishment from UK to a non resident company: further deferral
- CIRD42060: Transfer of non UK trade between EU companies
- CIRD42065: Transfer of non UK trade between EU companies: meaning of terms
- CIRD42080: Formation of a European company (SE)
- CIRD42090: The genuine commercial transaction requirement
- CIRD42100: Advance clearances: general
- CIRD42110: Advance clearances: requirements, time limits and appeals
- CIRD42115: Common reasons for refusal
- CIRD42120: Transfer of life assurance business
- CIRD42130: Transfer of building society business
- CIRD42140: Amalgamation of business of building societies, industrial and provident societies and co-operative associations
- Close sectionCIRD43000: Intangible assets: disincorporation relief: post-FA 2002 goodwill
- CIRD43050: Introduction
- CIRD43100: Conditions for relief
- CIRD43150: Effect of disincorporation relief: overview
- CIRD43200: Effect of disincorporation relief on company: computation: goodwill written-down for tax
- CIRD43250: Effect of disincorporation relief on company: computation: goodwill on balance sheet but not written-down
- CIRD43300: Effect of disincorporation relief on company: computation: goodwill not on balance sheet
- CIRD43350: Effect of disincorporation relief on shareholders: Capital Gains rules
- CIRD43400: Making a claim
- Close sectionCIRD44000: Restrictions for goodwill and relevant assets
- CIRD44050: Introduction
- CIRD44055: Introduction to FA19 rules
- CIRD44060: Definition of relevant assets and qualifying IP assets
- CIRD44065: Summary of when the restrictions apply
- CIRD44070: Nature of full restriction
- CIRD44075: Pre-FA 2019 relevant assets - introduction and the first case
- CIRD44076: Pre-FA 2019 relevant assets - the second case
- CIRD44077: Pre-FA 2019 relevant assets - second case examples
- CIRD44078: Pre-FA 2019 relevant assets - the third and fourth cases
- CIRD44080: No business or no qualifying IP acquired
- CIRD44083: Acquisitions from a related individual or firm
- CIRD44086: Partial restriction in relation to qualifying IP assets
- CIRD44090: Partial restriction in relation to acquisitions from a related individual or firm
- CIRD44093: The partial restrictions on debits
- CIRD44096: The partial restriction on realisations
- CIRD44100: F2A15 rules
- CIRD44150: Circumstances when F2A15 rules will apply
- CIRD44200: How accounting and other debits are restricted under F2A15
- CIRD44250: F2A15 realisations
- CIRD44300: FA15 rules for goodwill and relevant assets acquired on incorporation from a related party or after 3 December 2014 - background to FA15 changes
- CIRD44350: Circumstances when FA15 rules will apply to a related party incorporation
- CIRD44400: FA15 restriction where there are no previous third party acquisition costs
- CIRD44450: Third party acquisition rules
- CIRD44500: FA15 rules - calculation of debits in respect of a relevant asset where there are previous third party acquisition costs
- CIRD44550: FA15 realisations - relief due on subsequent realisation of a relevant asset where there are no previous third party acquisition costs
- CIRD44600: FA15 realisations - apportionment of debit in respect of relevant asset where there are previous third party acquisition costs
- CIRD44650: FA15 - computational examples
- Close sectionCIRD45000: Intangible assets: related party rules
- CIRD45010: Introduction
- CIRD45020: Circumstances where relevant
- CIRD45030: Market value rule: general
- CIRD45033: Market value rule: transfers giving rise to a distribution or employment income charge
- CIRD45035: Market value rule: transfers where CGT gifts hold-over relief is claimed
- CIRD45040: Market value rule: interaction with transfer pricing code
- CIRD45105: Statutory definition: outline
- CIRD45120: Statutory definition: comparison with ‘connected person’
- CIRD45130: Persons treated as related parties: subject to insolvency arrangements
- CIRD45150: Definition of control: general
- CIRD45160: Definition of control: major interest
- CIRD45180: Definition of control: power to attribute interests of one person to another: general
- CIRD45190: Definition of control: power to attribute interests of one person to another: ‘connected persons’
- CIRD45195: Definition of control: power to attribute interests of one person to another: other than by virtue of ‘connected person’ test
- CIRD45200: Interest held jointly
- CIRD45250: Participator in close company
- CIRD45260: Related party rules: partnership incorporation of a pre-FA 2002 business: outline
- CIRD45265: Related party rules: partnership incorporation of a pre-FA 2002 business: technical arguments
- CIRD45270: Related party rules: partnership incorporation of a pre-FA 2002 business: establishing the facts
- CIRD46000: Intangible assets: special rules for restricted assets: contents
- Close sectionCIRD47000: Intangible assets: international issues
- CIRD47010: Introduction
- CIRD47020: Company becomes resident in UK or asset starts to be used in a permanent establishment in the UK
- CIRD47030: Company ceases to be resident in UK or asset ceases to be used in a permanent establishment in the UK
- CIRD47040: Company ceases to be resident in UK: deferral of taxable credit: general
- CIRD47050: Company ceases to be resident in UK: deferral of taxable credit: subsequent part-realisation of asset
- CIRD47060: Application of transfer pricing rules
- CIRD47070: Intangible assets attributable to a foreign branch
- Close sectionCIRD48000: Intangible assets: avoidance
- CIRD48010: Introduction
- CIRD48020: Structural defences and their limitations
- CIRD48030: Specific rules
- CIRD48040: More general CT rules
- CIRD48050: Change of ownership of company
- CIRD48105: Tax-driven transactions: approach to take
- CIRD48110: Tax-driven transactions: outline of provision
- CIRD48120: Tax-driven transactions: relationship of anti-avoidance rule with other provisions
- CIRD48130: Tax-driven transactions: whether tax avoidance main object
- CIRD48140: Tax-driven transactions: circumstances where anti-avoidance rule may be in point
- CIRD48150: Tax-driven transactions: nature of counteraction
- CIRD48200: Measures in FA 2003, s 184: background
- CIRD48230: Measures in FA03/S184: how they work
- CIRD48250: Measures in FA03/S184: position for accounting periods ending at different times
- CIRD48260: Measures in F2A05/S41: change to rules: market value rules
- CIRD48270: Measures in F2A05/S41: change to rules: related parties rules
- CIRD48280: New measures in FA 2006, s 77: change to rules: new assets derived from companies' pre-FA 2002 assets
- CIRD48290: New measures in FA 2009, s 70: confirmation of rules: time of creation of goodwill and certain other internally generated assets
- CIRD48300: New measures in FA11/S62: confirmation of rules: goodwill and intangible assets relating to an oil & gas licence excluded
- CIRD48320: Intangible assets exchanged for other assets recognised at net book value (step-up schemes)
- CIRD48330: Accounting step-up schemes involving transfers
- CIRD48340: Intangible asset realisation involving non-monetary receipts
- CIRD48350: Related party licence not granted at market value
- CIRD48360: Related party licence examples
- Close sectionCIRD49000: Intangible assets: just and reasonable apportionment
- Close sectionCIRD10100: Intangible assets: introduction
- Close sectionCIRD60000: Remediation of contaminated land
- Close sectionCIRD60005: Outline
- CIRD60010: Land Remediation Relief - Outline - Periods to 31 March 2009
- CIRD60015: Land Remediation Relief from 1 April 2009 - Outline - Land in a Contaminated state
- CIRD60020: Land Remediation Relief from 1 April 2009 - Outline - Derelict Land
- CIRD60025: Land Remediation Relief from 1 April 2009 - Outline - Arsenic, radon and Japanese knotweed
- Close sectionCIRD60050: Land Remediation Relief - detailed guidance
- CIRD60051: Acquiring land
- CIRD60055: Timing of relief
- CIRD60060: Claims
- CIRD60062: Late claims
- CIRD60065: Real Estate Investment Trusts
- CIRD60070: Capital expenditure
- CIRD60075: The election
- CIRD60080: Pre commencement expenditure
- CIRD60085: Capital Allowances
- CIRD60090: Capital Gains
- Close sectionCIRD61000: What is “land in a contaminated state”?
- CIRD61001: What is ”land in a contaminated state”? - up to 31 March 2009
- CIRD61010: What is “land in a contaminated state”?: Examples
- CIRD61015: What is “land in a contaminated state”?: Japanese Knotweed
- CIRD61020: What is “land in a contaminated state”?: Japanese Knotweed - change of view
- CIRD61025: What is “land in a contaminated state”?: Burials
- CIRD61030: What is “land in a contaminated state”?: Voids and spaces
- CIRD61035: What is “land in a contaminated state”?: Flood prevention
- CIRD61040: What is “land in a contaminated state”?: Landscaping and earthworks
- CIRD61045: What is “land in a contaminated state”?: Ground gases
- CIRD61200: What is ”land in a contaminated state”? - from 1 April 2009
- Close sectionCIRD62000: Derelict Land
- Close sectionCIRD63000: Qualifying Land Remediation Expenditure
- Close sectionCIRD68000: Tax Credit
- CIRD68005: Qualifying land remediation loss
- CIRD68010: Qualifying land remediation loss - unrelieved losses
- CIRD68015: Qualifying land remediation loss - example
- CIRD68020: Restriction of losses carried forward
- CIRD68025: Amount of tax credit
- CIRD68030: Claims
- CIRD68035: Amended claims
- CIRD68040: Set off against corporation tax
- CIRD68045: Arrears of PAYE or NI
- CIRD68050: Interest
- CIRD68055: Enquiries into returns
- CIRD68060: Changes in qualifying land remediation loss
- CIRD68065: Recovery of tax credit
- CIRD68070: Chargeable gains
- Close sectionCIRD69000: Definitions
- Close sectionCIRD60005: Outline
- Close sectionCIRD70000: Telecommunications licences and rights
- CIRD70105: Introduction: how the guidance is organised
- CIRD70110: Introduction: outline
- CIRD70150: Introduction: the legislation: FA 2000, s 87
- CIRD70155: Introduction: the legislation: FA 2000, Sch 23
- CIRD70305: Wireless telegraphy licences: background
- CIRD70320: Wireless telegraphy licences: auctions
- CIRD70330: Wireless telegraphy licences: further information
- CIRD70340: IRUs: background
- CIRD70350: IRUs: particular points
- CIRD70355: IRUs: granting of
- CIRD70360: Wireless telegraphy licences and IRUs: derived rights
- CIRD70400: How the legislation works: introduction
- CIRD70405: How the legislation works: expenditure on acquisitions
- CIRD70410: How the legislation works: receipts from disposals
- CIRD70415: How the legislation works: revaluations
- CIRD70420: How the legislation works: traders and non-traders
- CIRD70505: Accounting and groups: ‘taken into account’
- CIRD70510: Accounting and groups: group accounts
- CIRD70600: Accounting and groups: commencement provisions
- CIRD70605: Accounting and groups: date of acquisition
- CIRD70610: Accounting and groups: acquisition from associates or associated companies
- CIRD70620: Accounting and groups: controlled foreign companies
- CIRD70705: Transition to intangible regime: transitional provisions (CT only)
- CIRD70710: Transition to intangible regime: reinvestment relief (CT only)
- Close sectionCIRD75000: Vaccine research relief: Contents
- CIRD75050: Introduction
- CIRD75100: Requirement that a company is a going concern
- CIRD75200: Qualifying expenditure: for an accounting period
- CIRD75300: Qualifying expenditure: on direct R&D
- CIRD75400: Qualifying expenditure: on sub-contracted R&D
- CIRD75500: Qualifying expenditure: on contributions to independent R&D
- CIRD75525: Subcontracting to charities, universities and scientific research organisations
- CIRD75550: Subcontracting to companies and others
- CIRD75600: How relief is given: SMEs
- CIRD75700: How relief is given: large companies
- CIRD75800: How relief is given: insurance companies
- CIRD75900: Inflated claims
- CIRD75950: Refunds of contributions and subcontract payments
- CIRD76000: Specified diseases: general
- CIRD76100: Specified diseases: tuberculosis and malaria
- CIRD76200: Specified diseases: HIV/AIDS
- CIRD76300: Definitions
- CIRD76400: Dealing with claims
- Close sectionCIRD80000: R&D tax relief
- CIRD80150: Overview
- CIRD80200: Background
- CIRD80250: Comparison of the basic features of the two schemes
- CIRD80260: R&D Rate tables
- CIRD80300: Help points and further guidance
- CIRD80350: R&D Compliance contact details
- CIRD80370: Updated Large Business practice note
- Close sectionCIRD80500: Examining a claim
- Close sectionCIRD81000: Conditions to be satisfied
- CIRD81100: Overview
- CIRD81130: Company a going concern (SME scheme only)
- CIRD81160: Total aid to project €7.5m or less (SME scheme 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 (SME scheme only)
- CIRD81700: Capital expenditure
- CIRD81800: Claims and time limits
- CIRD81805: Restriction of nominations and assignments
- CIRD81900: DTI guidelines (2004) - text
- CIRD81910: DSIT guidelines (2023) - text
- CIRD81920: DTI guidelines (2004) - application to pharmaceuticals
- CIRD81960: DTI guidelines (2004) - application to software
- CIRD81980: Case Studies demonstrating R&D tax credit claims for software projects
- Close sectionCIRD82000: Categories of qualifying expenditure
- CIRD82100: Overview
- CIRD82150: Connected persons
- CIRD82200: Contributions to independent research
- CIRD82250: Contributions to independent research: qualifying bodies
- CIRD82300: Consumable items
- CIRD82400: Consumable items: meaning of consumed or transformed
- CIRD82450: Consumable stores
- CIRD82500: Software
- CIRD83000: Staffing costs
- CIRD83200: Staffing costs: measure of
- CIRD83250: Staffing costs: ITEPA benefits in kind changes in 2003
- CIRD83800: Staffing costs: employee partly engaged on R&D
- CIRD84000: Externally provided workers
- CIRD84050: Externally provided workers: connected staff supplier
- CIRD84100: Externally provided workers: definition
- CIRD84200: Subcontracted activities
- CIRD84250: Subcontracted activities: meaning of subcontracted
- CIRD84400: Application to clinical trial volunteers
- Close sectionCIRD85000: Large company scheme
- Close sectionCIRD89700: R&D Expenditure Credit (RDEC) Scheme
- CIRD89705: R&D Tax reliefs: R&D expenditure credit (RDEC) Scheme: overview
- CIRD89710: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: calculation of credit
- CIRD89720: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: groups
- CIRD89730: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: refunds of contributions to independent research and subcontract payments
- CIRD89740: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: claims by SME
- CIRD89750: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: R&D contracted to a SME
- CIRD89760: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: subsidised qualifying expenditure
- CIRD89770: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: qualifying R&D expenditure
- CIRD89780: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: payment of credit
- CIRD89790: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: restriction of total expenditure on R&D workers' PAYE and NIC
- CIRD89800: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: total amount of company's PAYE and NIC liabilities
- CIRD89810: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: surrender of credit to another group company
- CIRD89820: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: payment restrictions; going concern requirement
- CIRD89830: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: insurance companies treated as large companies and I-E basis
- CIRD89840: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: artificially inflated claims for credit
- CIRD89850: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: company as a member of a partnership
- CIRD89860: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: interaction with other reliefs
- CIRD89870: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: effect on quarterly instalment payments (QIPs)
- CIRD89880: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: capitalised revenue expenditure
- CIRD89890: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: frequently asked questions
- CIRD89900: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: notes to expenditure and examples
- CIRD89910: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: notes to R&D expenditure credit (RDEC) for examples 1-4
- CIRD89920: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: example 1 profit-making company in receipt of RDEC
- CIRD89930: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: example 2: loss making company in receipt of RDEC)
- CIRD89940: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: example 3: profit-making company but RDEC exceeds liability
- CIRD89950: R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: example 4: loss making year 1 profit making year 2
- Close sectionCIRD90000: SME scheme
- CIRD90050: Overview
- CIRD90100: Conditions
- CIRD90200: Pre-trading expenditure
- CIRD90300: How relief is given
- CIRD90400: Restriction of consortium relief
- CIRD90500: Payable tax credit - for surrenderable loss
- CIRD90600: Payable tax credit - restriction of the credit
- CIRD90700: Payable tax credit - recovery of
- Close sectionCIRD91000: SME definition
- CIRD91100: Introduction
- CIRD91200: Enterprises
- CIRD91300: 1996 EC SME Recommendation tests
- CIRD91400: 2003 EC SME Recommendation tests
- CIRD91500: Aggregation for 2003 EC SME Recommendation tests
- CIRD91600: Linked enterprises for 2003 EC SME Recommendation tests
- CIRD91700: Partner enterprises for 2003 EC SME Recommendation tests
- CIRD91800: Headcount, turnover and balance sheet total
- CIRD91900: increases in thresholds
- CIRD92000: Change of status
- CIRD92100: Venture capital company
- CIRD92200: Institutional investor and public investment corporation
- CIRD92300: Capital for the purposes of EC SME Recommendations
- CIRD92400: Voting rights for the purposes of EC SME Recommendations
- CIRD92500: Control for the purposes of EC SME Recommendations
- CIRD92550: Control by venture capital companies
- CIRD92700: Text of 1996 EC SME Recommendation 1996/280/EC
- CIRD92800: Text of 2003 EC SME Recommendation 2003/361/EC
- CIRD92850: SME status flowchart for 2003/361/EC
- Close sectionCIRD97000: Avoidance
- Close sectionCIRD98000: Legislative structure and time line
- CIRD98050: Overview
- CIRD98100: SME scheme
- CIRD98200: Large company scheme
- CIRD98300: FA03 changes
- CIRD98400: FA04 changes
- CIRD98500: IAS changes
- CIRD98550: FA06 changes
- CIRD98560: FA07 changes
- CIRD98570: FA08 changes
- CIRD98580: FA10 changes
- CIRD98590: FA11 changes
- CIRD98600: FA12 changes
- CIRD98610: FA13 changes
- CIRD98620: FA14 changes
- CIRD98630: FA15 changes
- CIRD98640: F(No. 2)A 15 changes
- CIRD98650: FA16 changes
- CIRD98900: Time line for changes
- Close sectionCIRD99000: Accountancy
- CIRD99500: Simple guide for small companies
- Close sectionCIRD100000: Reformed reliefs: contents
- Close sectionCIRD200000: Patent Box
- Close sectionCIRD200100: Overview of the Patent Box regime
- Close sectionCIRD201000: Reduced CT rate for profits from patents
- Close sectionCIRD210000: Qualifying companies
- CIRD210100: Qualifying companies: meaning of ‘qualifying company’
- CIRD210110: Qualifying companies: meaning of ‘qualifying IP right’
- CIRD210120: Exclusive licence: meaning of ‘exclusive licence’
- CIRD210130: Exclusive licence: non-commercial or unnecessary terms
- CIRD210140: Exclusive licence: exclusivity requirement
- CIRD210145: Exclusive Licence: exclusivity requirement: further examples
- CIRD210150: Qualifying IP rights: rights to which Part 8A applies
- CIRD210160: Qualifying IP rights: EEA qualifying patent jurisdictions
- CIRD210170: Patent Box: qualifying companies: qualifying IP rights: other rights to which Part 8A applies: Supplementary Protection Certificates and Marketing Authorisations
- CIRD210175: Patent Box: qualifying companies: qualifying IP rights: other rights to which Part 8A applies: plant breeders' rights, plant variety rights, and plant protection products with data protection benefits
- CIRD210180: Qualifying IP rights: items to which patent relates
- CIRD210190: Qualifying IP rights: meaning of ‘qualifying development’
- CIRD210200: Qualifying IP rights: development conditions A to D
- CIRD210210: Groups: active ownership condition
- Close sectionCIRD220000: Relevant IP profits
- CIRD220100: Relevant IP profits: overview
- CIRD220130: relevant IP profits: finance income and excluded income
- CIRD220150: Relevant IP income: sub contents
- CIRD220430: Routine return figure
- CIRD220440: Routine return figure: routine deductions
- CIRD220450: Routine return figure: deductions that are not routine deductions
- CIRD220460: Routine return figure: example
- CIRD220470: Elections for small claims treatment: entry criteria
- CIRD220480: Elections for small claims treatment: small claims amount
- CIRD220490: Marketing assets return figure
- CIRD220500: Marketing assets return figure: notional marketing royalty
- CIRD220510: Marketing assets return figure: notional marketing royalty: assumptions
- CIRD220520: Marketing assets return figure: notional marketing royalty: examples
- CIRD220530: Marketing assets return figure: actual marketing royalty
- CIRD220540: Profits arising before grant of right
- CIRD220550: Patent Box: relevant IP profits: profits arising before grant of right: how relief is given
- Close sectionCIRD240000: Relevant IP losses
- CIRD240100: Relevant IP losses: overview
- CIRD240130: relevant IP losses: order of set off: allocation to other trade or within a group
- CIRD240140: Set off amount: carry-forward
- CIRD240150: Company ceasing to carry on trade
- CIRD240160: relevant IP losses and inheritance of R&D fraction: Transfer of a trade or part trade
- CIRD240170: Payments between group members for allocation
- Close sectionCIRD250000: Anti-avoidance
- Close sectionCIRD260000: Supplementary
- Close sectionCIRD270000: Patent Box: calculation steps and examples: contents
- CIRD270300: Patent Box: patent pending calculations: Are my qualifying IP rights in the old or new regime: examples
- CIRD270200: Patent Box: patent pending calculation: Are my qualifying IP rights in the old or new regime?
- CIRD271000: Patent Box: patent pending calculation: Transitional provisions from the old regime
- CIRD271600: Patent Box: patent pending calculation: Products containing both old and new IP
- CIRD271100: Patent Box : transfer of trade
- CIRD271500: Patent Box: Considering streaming income requirement
- CIRD272000: Patent Box: Tracking and tracing R&D expenditure
- CIRD272100: Patent Box: nature of records to keep for tracking and tracing
- CIRD272200: Patent Box: when to start tracking and tracing R&D expenditure
- CIRD273100: Patent Box: small claims treatment for notional royalty appropriate percentage
- CIRD273200: Patent Box : small claims treatment for global streaming
- CIRD274000: Patent Box: R&D fraction: contents
- CIRD275000: Patent Box : Calculation Flowchart
- CIRD275100: Patent Box: Calculation steps preparation
- CIRD275200: Patent Box: Streaming calculation steps
- CIRD275300: Patent Box, examples of streaming calculations
- CIRD275500: Patent Box: using the Value Fraction in exceptional circumstances
- CIRD276000: Patent Box: Cost Sharing Arrangements (CSAs): contents
- CIRD277000: Patent Box: example of Patent Box calculation