Corporation Tax Act 2009 Schedule 2 para 115

Expenditure incurred before 22 April 2003

Paragraph 115 of Schedule 2 establishes a cut-off date for the availability of R&D tax relief for vaccine research expenditure under Chapter 7 of Part 13, restricting it to expenditure incurred on or after 22 April 2003.

• Chapter 7 of Part 13 provides R&D tax relief specifically for vaccine research carried out by both SMEs and large companies.
• This relief is not available for any expenditure incurred before 22 April 2003, regardless of when a claim is made.
• Pre-trading expenses that are treated as incurred on the first day of trading under section 61 cannot be used to circumvent this date restriction.
• The practical effect is that only vaccine research spending from 22 April 2003 onwards qualifies for relief under these provisions.