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HMRC internal manual

Corporate Intangibles Research and Development Manual

HM Revenue & Customs
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R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: insurance companies treated as large companies and I-E basis

Chapter 6A CTA 2009 S104U and V

Insurance companies can claim an RDEC by virtue of FA2012. This section applies where an insurance company carries on life assurance business and is a SME in the period.

This section applies when profits are calculated on the I-E rules and the charge to tax does not include any BLAGAB (Basic Life Assurance and General Annuity Business) trade profits or losses.

Any RDEC is treated as a deemed I-E receipt as if it had been taken into account in calculating the company’s BLAGAB profit or loss.