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HMRC internal manual

Corporate Intangibles Research and Development Manual

R&D Tax reliefs: R&D expenditure credit (RDEC) scheme: company as a member of a partnership

See CIRD81220

Companies may carry out R&D as members of a partnership. The expenditure credit is claimed by the individual corporate partner in the CT600 return on their share of the R&D expenditure incurred and accounted for as a taxable receipt in the company accounts.

For the R&D to be relevant R&D it must be related to a trade carried on, or to be carried on, by the partnership, subject possibly to the rules on group purpose as indicated in CIRD89720. If the R&D would be relevant R&D for the partnership if it were treated as a company and, under that premise, it would be treated as a member of a group then the relevant ‘R&D for group’ tests could be applied.

In any cases where the interpretation of these rules causes problems in arriving at the necessary modifications to allow a partnership to be tested as though it were a company, HMRC officers should seek advice from CT International & Stamps.