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HMRC internal manual

Company Taxation Manual

Particular bodies: Pharmaceutical cases: Definition

A working definition of a pharmaceutical (“pharma”) case is set out below:


  • Any manufacturer of human or veterinary medicines (whether prescription only or not), or materials used in medical diagnostics
  • Any manufacturer of drug delivery systems or of aids to surgery or other medical interventions
  • Any distributor connected to a pharmaceutical manufacturer
  • Any contract research organisation, or contract manufacturer, working to the pharmaceutical industry
  • ‘Virtual pharmas’, that is companies which acquire or develop medicines, but use other organisations for some or all of the R&D, manufacturing or marketing.
  • Biotechnology or life science companies. This is an emerging area that is not easy to classify. Most biotech companies include the development of medicines, or the provision of specialist services to pharmaceutical companies, as one of their business purposes. A significant minority, however, are concerned only with other processes, for example, microbial quality control for the food industry, environmental monitoring, or plant nutrients or protection. Usually the description in the directors’ report should make this clear, but if this still remains in doubt, assume the case to be a pharmaceutical one.

Where one company in a group meets the definition of a pharma case, then the wholegroup should be concentrated in the designated pharma office (determined by the registeredoffice of the parent company).


  • Retail pharmacists
  • Wholesalers and distributors of drugs which


    • acquire no proprietary interest in the products they sell, and
    • are not part of a group which includes a pharmaceutical manufacturer (whether in the UK or abroad).