Corporation Tax Act 2009 section 1132

External workers: attributable expenditure

Section 1132 sets out the rules for determining when qualifying expenditure on externally provided workers can be treated as attributable to relevant research and development.

• Qualifying expenditure on external workers is attributable to R&D only where those workers are directly and actively engaged in the relevant research and development activities
• Where an external worker splits their time between R&D and non-R&D duties, only the appropriate proportion of the qualifying expenditure relating to that worker is treated as attributable to R&D
• Persons providing support services, such as secretarial or administrative services, in support of R&D activities are not treated as being directly and actively engaged in those R&D activities
• This section mirrors the equivalent rules for staffing costs, ensuring a consistent approach to attributing expenditure across different categories of R&D spend